ML20134A491
Text
~
e e
o e
g Neg l ofiS SEP 2 3 gggy OPA ELD ACRS ASLBP ASLAP EDO ME!GRANDUM FOR:
The Commission EDO R/F FROM:
William J. Dircks NRR Executive Director for Operations RES SUSJECT:
CLARIFICATION OF SECi-82-352 On August 20, 1982, I signed and forwarded SECY-82-352 to ir.fccm the Comission of staff initiatives to improve the assur2n:e of quality in the design and construction of nuclear projects.
I would like to clarify the staff's intent as stated in the " Purpose" and "Recorc,endation" sections of the SECY paper.
The following staff initiatives have been approved within the authority of the Executive Director for Operations and are presently in varying stages of ireple-cantation.
For these initiatives, the staf f intends cnly to inf tm the Ccr.,ission of the selection and substance of each initiative.
NTOL - Self Evaluation NT0L - Regional Evaluation f4TOL - Independent Design ;,cviea Industry Initiative Construction Inspection Prograr Char.ges Construction Assessnent Tear Inspections integrated Design Inspections Evaluation of Ecported Inforr.ation l'.anagenent and Quality Improvement Programs Qualification and Certification of OA/QC Personnel Craftsmanship Long Tem Review Quality Assurance Plcnning and Evaluation The remaining staff initiative, " Designated Represer,t5tives," invcives both complex legal questions and revisicn of iiRC's statutory authority.
The staff intends that the Cor.iission review and soprove the staf f's recm r dation to pursue the appropriate statutory revisions.
If approval is forthco:..ing, a subsequent action paper will be developed for Com.ission revies and approval containing prepased statutory revisions.
9508150324 e50703 (STM Eiilam J. Dirds PDR FDIA iLEIGHTOB4-293 PDR
,l5))5,.. A Dir.-ks E>.e:utive Dire;;c e fer r rcti ns b M M M L)I70 CC:
SECY prylgen ]n nrng. gpp rrril]e 3 n:c
- I[.. IE i
IE.
- E
- E
- .C J,
"m
..j arpsgr
,yereen eze.
- 4..-: s
,=
,7
- ieg i c,7 3 t uL An re, u.
s
pf. a n e u1'e UNITED sT ATEs s
g d@r.y g[ g NUCLEAR REGULATORY COfot/.lSSION Eq g
__/
j wAssincTon. o. c. 20sss
\\*'
- /
~
September 28, 1982 MEMORAtiDUM FOR:
Chairman Palladino Comissioner Gilinsky
. Comissioner Ahearne Comissioner Roberts Comissioner Asselstine FROM:
John E irector Offic of licy Evaluation
SUBJECT:
ASSURAtiCE OF QUALITY (SECY-82-352)
As requested by Comissioner Gilinsky on September 24, we have evaluated the staff QA initiatives presented in SECY-82-352. The initiatives are a result of an effort by the staff to critically examine breakdowns in industry quality assurance.
We believe the initiatives identified by the staff in SECY-82-352 are major steps forward as the tiRC comes to grips with these problems in the quality assurance area. The staff understands that the
. initiatives are only part of the answer to such problems, and proposes -- and we agree -- further study of the problems while the proposed initiatives are being implemented.
The' staff attributes the recent breakdowns in industry quality assurance primarily to "a lack of total management commitment to quality at the nuclear project's inception." The staff believes -- and we agree -- that if utility senior management has a strong comitment to quality, and if that commitment is imbued in a capable project management team, then the subsequent actions The of this team will communicate that commitment tc all involved parties.
project management team communicates and obtains through contractual and procedural arrangements with the designers, fabricat' ors, and constructors a level of quality commensurate with the owner's commitment.
Our comments below first address QA responsibilities of licensees and applicants, the Comission, and the tiRC overall, and then focus on the specific initiatives identified in SECY-82-352.
Also covered below are addi~tional OPE observations which build upon the staff initiatives.
RESP 0tiSIBILI.TY FOR QUALITY Licensee and Aoplicant The majority of the initiatives in SECY-E2-352 involve staff actions, i.e.,
While additional staff inspections and revisions to the inspection program.
the staff reaffirms that the underlying principle of their development has
Contact:
A. Kenneke, OPE X43302 fo/A -f4-393 J. Milhoan, OPE e ' ' " V'T' O u ~
17/
^-
~Y~'
y/,32c:
W
s To the Cormission 2
~
been that the ultimate responsibility for quality and safety remains within the nuclear industry, and states that none of the initiatives are intended to transfer this responsibility to the NRC, nevertheless some may view the staff initiatives as supplanting to some degree licensee and applicant responsibility for quality.
We believe that the Commission should act, perhaps by means of a policy statement, to again emphasize that we hold licensees and applicants responsible for the quality of their plants.
Commission The staff indicated that all initiatives, with the exception of that concerning " designated representatives," have been undertaken under the authority of the _EDO.
We believe that the EDO should be ccamended for moving forward with the initiatives.
However, to assure that the Commission is taking a full and active role in quality assurance, we recommend that the Commission explicitly endorse the staff's initiatives, subject to any modifications to the EDD-approved initiatives that the Commission believes appropriate.
Again, a policy statement can serve as an appropriate mechanism.
NRC Overall In principle, NRC's responsibility for quality assurance involves all actions of the NRC to assure that all NRC requirements are met.
The staff states that:
"The NRC presently views responsibility for quality assurance as threefold:
first, to determine the adequacy of the licensee's quality assurance program description contained in the safety analysis report; second, to ascertain that the licensee has established and adequately implemented the approved quality assurance program and to verify compliance with NRC regulations; and third, to develop the regulations, standards and guides addressing QA in the design, construction and operation of nuclear facilities."
We believe that the staff's statement,is a practical view of NRC's responsibility.
COMMENTS ON INDIVIDUAL INITIATIVES The initiatives deal with the following:
organizational realignment, designated representatives, measures at near-term operating license facilities, industry action, construction inspection program, management and long-term review.
Each of these is discussed separately below.
Orcanizational Realionment.
The responsibi]ity for NRC quality assurance functions has been divided among three separate offices, NRR, IE and RES, respectively, with execution of the inspection function from the five regional offices.
These three functional areas are not separate and discrete areas but are highly interrelated,
1 To the Commission 3
requiring continual interface. NRC headquarters activities which relate to the development of NRC policy, rules, standards and guides, and review and evaluation of the implementation of licensee QA programs are being consolidated at this time within the Off. ice of Inspection and Enforcement.
The licensing function is to remain in NRR until the current backlog of licensing actions is completed.
Commissioner Ahearne has asked the staff why the NRR QA Branch function should not be transferred to IE.
Although we believe that the planned organizational realignment is in the right direction, in a number of respects it is not obvious that, at this time 3t least, the realignment goes far enough.
The Commission may wish to get more background on these from the staff at the briefing.
1.
One of the p'rinciples of quality assur.ance is that management should provide a reporting level for persons performing quality related functions that will result in a clear level of authority to get results.
Assuming that the headquarters quality assurance functions are consolidated at the branch level within IE, there may be a basis for discussing whether there is sufficient authority vested in this group to accomplish the desired functions.
It'is noted thht inspections of quality assurance program implementation, for the most part, will be carri.ed out separately in the field under Regional Administrators.who report to the EDO.
2.
One of the stated reasons for the organizational realignment is "to provide industry a signal that NRC considers quality a leading part of the NRC operation and of sufficient importance to depart from the existing organizational structure." However, with the headquarters consolidation occurring at the branch level within IE, some may feel that quality assurance is not being placed at a sufficiently nigh level to reflect NRC's view of its importance. We noted that emergency planning when consolidated was placed at the Division level; QA would appear to be comparable in importance.
Desianated Representatives The staff requests Commission approval to pursue revision of the NRC's statutory authority to allow implementation of a system of designated representatives. analogous to the system employed by the Federal Aviation Administration (FAA).
The aviation industry uses hold points in the manufacturing process for inspection and certification by an FAA inspector before the process can continue.
The FAA uses designated representatives, provided by the aviation industry and acting for the FAA, to conduct the inspections and provide the necessary certification.
The staff concludes that a similar technique of using designated representatives could be useful to the NRC inspection effort, as it could increase the effective number of inspectors available to implement the inspection program by providing an
To the Commission 4
I imediate source of qualified experienc'ed personnel.
The staff indicates that using designated representatives to check key aspects of the design, fabrication and construction of a plant at the specific time that increased inspection effort is warranted could significantly raise liRC's level of confidence in quality assurance at nuclear power plants.
The staff concludes that the Commission does not have the authority to designate licensee personnel as' inspectors in a manner similar to the FAA.
The staff proposes to pursue the statutory changes necessary to implement a designated representative program and to continue development of program
,Jpecifics.
In this regard, Comissioner Ahearne has requested that the staff provide specifics on the designated representative proposal, including criteria for selection of designated representatives, who would pay the designees, who would supervise them, overlap with the certification concept, and FAA experience to date.
We believe that the designated representative initiative represents a bold, forward-looking approach to providing additional direct inspection resources in a time of tight budget constraints.
We reccmend that the Comission allow the staff to go forward with steps to have the Atom'it Energy Act amended and to develop proposed regulation changes which would implement such Atomic Energy Act amendments.
We note that, if the Comission allows the staff to pursue this initiative, a separate action paper will be developed for Comission review and approval containinc proposed statutory revisions.
Measures at fiear-Tem Operating License (liTOL) Facilities The staff proposes to continue to employ the measures currently in use to establish confidence in the quality and effectiveness of utility quality assurance programs at fiTOL facilities until other fiRC or industry programs are capable of providing this confidence. These measures include applicant self-evaluation, independent design review, any regional evaluations.
Applicants have the responsibility to demonstrate confidence in the quality and effectiveness of its quality assurance program.
In making a decision to discontinue the liTOL initiatives, we believe the staff should assure itself that applicant responsibility is not being supplanted by the fiRC or IfiP0 activities.
In particular, a decision to discontinue the fiTOL initiatives should be based on the assumption that the applicant will continue to have in place measures at least equivalent to the fiTOL self-evaluation and the
~
independent design review. Lastly, we assume that the certification by the applicant's. Chief Executive Officer or his designee that the facility has been designed, constructed and tested in accercance with the Final Safety Analysis Report and other licensinc comitments will continue irrespective of changes in other tiTOL measures, as such certification emphasizes applicant responsibility' for its facility.
~
To the Comission 5
Industry Initiative The staff briefly describes a program being developed by IfiPO with respect to quality assurance for design and construction.
It was indicated in SECY-82-352 that details of the staff involvement have not yet been developed.
We believe that, once details and direction of the IriP0 program are settled, a Memorandum of Un,derstanding may be appropriate to for:nalize staff involvement with the I!1PO process. We understand that the staff plans to develop such a Memorandum of Understanding.
.. Construction Inspection Procram The staff propose.s four changes to the construction inspection program:
Procedure Chances.
The staff states that the fiRC does not have sufficient inspection resources to fully implement all of the existing procedures in the reactor construction inspection program. The staff will allocate an additional 0.3 staff years in FY 83 and an additional 0.2 staff years in FY 54 to each construction project to execute the constructi.on inspection procedures, and will revise the individual inspection procedures for the various technical disciplines to better catch the budgeted resources.
Construction Assessment Team (CAT) Inspections.
The staff will extend the concept of tne tiRC's Performance Appraisal Team (PAT) inspection program for cperating reactors to about four selected plants under construction per year.
Intecrated Desian Inspections. The staff is developing an inspection approach wnich provides e comprehensive examination of the design development and implementation for a selected system and structure on a given project.
Evaluation of Reported Information.
The fiRC will expand its capability to Toent1Ty generic cesign end construction deficiencie,s by computerized analysis of information reported by vendors, construction permit holders and liRC insp ctors.
.We believa each of these construction inspection program initiatives are worthwhile.
With respect to integrated design inspections, however, we should be careful that applicants do not think that we are relieving them of their responsibilities for design, but understand that such inspections are intended to measure how well they are exercising their responsibilities.
We note that Comissioner Ahearne has asked the staff to explain how fiRC will implement the integ;ated design inspection idea.
Comissioner Ahearne also recuested the staff to discuss procedure changes in the reactor construction inspection program.
l 1
1
i To the Comission 6
Manacement and Ovality Improvement Proa' ram The staff stated that it will cooperate with the nuclear industry in sponsoring quality management seminars for top-level managers with facilities under design and construction; that each utility with a, facility under construction will b'e requested to reevaluate its quality assurance program and implement improvements in areas where the evaluations identify a need; that liRC will take actions to improve the enforcement of existing standards for qualification of quality assurance and quality control personnel, and to pursue establishment of a system of third-party qualification and certification for such personnel; and that fiRC will continue to explore with labor and other organizations potential methods and incentives to assure quality in design. and construction-related production activities.
With respect to seminars, we recommend participation of Commissioners in such seminars to emphasize the importance the Comission places on quality assurance.
With respect to utility reevaluation of its cuality assurance program, we believe that such a request should take into account the self-evaluations perfomed by itTOL applicants so that that effort is not duplicated.
With respect to qualification and certification of QA/QC personnal, the staff -
states that this has been a significant and prevalent problem, that some utilities have waived, without suitable bases, the education and experience requirements for such persennel and that tiRC has not sufficiently enforced these requirements through its inspection efforts.
In light of these problems, the staff initiative appears very appropriate.
We note that formal certification of various levels of QA/QC personnel will be considered as part of the long-term review.
Lone-Tem Review The staff states that long-tem liRC quality assurance policies and programs will be based on a review which assesses existing agency and industry quality assurance activities in a broad manner and then recomends an intearated long-tem agency plan for quality assurance. 'The staff also states this review will include a detailed assessment of the problems that developed at facilities such as Diablo Canyon, South Texas, Midland, fiarble Hill, and Zimer.
The objective of this assessment will be to identify, as concisely as possible, specific problems that have occurred and their root causes, particularly in the area of programatic ceficiencies.
Additionally, the review will evaluate existing programs at facilities which have programs that are functioning properly, in order to identify the positive aspects of those procrats that should be applied generically.
We understand that it may take about one year to complete the long-term review and that the revies will be ~~
conducted by the fiRC staff and will include representatives from headquarters, the regional offices, and c:nsultants to the fiRC. We believe that it is important also to obtain durin; the long-te= review input from
To the Comission 7
resident and regional inspectors and fr'om utilities.
It appears the staff plans to obtain this input.
We believe the long-term review proposed by the staff is appropriate.
ADDITIONAL OBSERVATIONS Schedules
'We note that very tight timelines have been proposed by the staff (see to SECY-82-352).
Further, we note that specific end dates for the various initiatives have not been proposed by the staff, rather timelines related to projected licensing schedules are given, and that seems entirely-appropriate at this stage.
However, we believe it would be appropriate for the Commission to receive periodic status reports, say quarterly, on progress in completing the initiatives.
Licensino, Research and Standards One could get the impression from SECY-82-352,that the NRC licensing, research and standards functions in the quality assurance area are without problems, that if we solve enforcement problems we have completed our work.
Although solutions to present enforcement problems are our first priority, improvements in the areas of licensing, research and standards should also be sought as part of the long-tem review.
Procurement The staff states that the owner's project management team communicates through contractual and procedural arrangements with the designers, fabricators and constructors to obtain a level of quality ccmensurate with the owner's commitment and that the commitment to cost and schedule must be properly balanced with quality through these contrac.tual and procedural a rrangements.
One of the conclusions reached at the ANS Executive Conference on Improving Quality in the Nuclear Industry was that the procurement process is important to quality and, if not properly controlled, can adversely impact quality.
As part of the long-term study we recommend that the contractual aspect of the procurement process receive additional staff review.
Less'ons Learned As a result of implementation of the initiatives presented in SECY-82-352 and performance of the long-term study, we should obtain valuable infomation which should be useful in reviewing the effectiveness of present nuclear quality assurance standards, not from the viewpoint of adding additional requirements, but from the viewpoint of simplifying and updating existing quality assurance standards.
Obviously, if existing nuclear quality assurance standards have deficient areas they should be corrected.
In any
A1 To the Commission 8
~
case, we should ensure that the lessons' learned are fed back into the American fiational Standards process.
TMI Action Plan The TMI Action Plan' (NUREG-0660) contains a number of actions related to quality assurance, i.e., Tasks I.F and II.J.
We recommend that the staff consider the quality assurance 'related tasks of the TMI Action Plan in their development of the integrated long-term agency plan for quality assurance, which could then supersede those tasks of the Action Plan.
Doeretional Quality Assurance The staff indicates that the SECY-82-352 initiatives are directed toward reactor facilities not yet licensed for operation and that further consideration will be given to operating reactors as part of the long-term review.
We believe it is very important to devote attention to operational quality assurance.
However, we believe that quality assurance for design and construction should receive priority in the short term.
We note that many of the lessons to be learned from the staff review of quality assurance for design and construction may be applicable to certain operational activities such as refueling and major modifications.
SUMMARY
OF RECOMMENDATIONS We recommend that the Commission consider:
1.
Publishing a policy statement which encompasses the following:
Indication of the importance the Commission places on quality-assurance.
Indication that the Commission still places responsibility for quality and safety upon licensees and applicants.
Indication of Commissier concurrence with or modification of staff initiatives approved within the authority of the EDO.
Indication of Commission approval for the staff to pursue revision of the NRC's statutory authority to allow implementation of a system of designated representatives analogous to the system employed by the FAA.
2.
Exploring the rationale for the organizational realignment.
3.
Requesting the staff to develop, once the details of the INFO program
~
- : $ t.
To the Commission 9
are finalized, a Memorandum of Understanding with INPO concerning INP0/NRC actions on quality assurance.
4.
Participating in the quality assurance management seminars.
5.
Requesting the staff to consider as part of the long-term study:
Improvement in the licensing, research, and standards areas of quality assurance The contractual aspects of the procurement process Methods' for feedback of lessons learned into the American National Standards process 6.
Requesting the staff to submit quarterly reports on progress in implementing the quality assurance initiatives.
cc:
L. Bickwit S. Chilk W. Dircks V. Stello R. DeYoung H. Denton o
e e
t
-f
'22. 253u X:C?.Z C:!C'~:.' :.
)
W m
D 3-e sl d\\'
\\
r
\\
CO!O!ISSION MEETING In da. W cf:
PUBLIC MEETING BRIEFING ON QUALITY ASSURANCE - SECY-82-352
\\
m m; Septeiber 29, i982 7 m.
1 - 85 n.
Washington, D.
C.
n
)
l
/
I
/
\\,'
(.
ALDERSOX R M4UlXE 4C a vi 4 ', :.
., s.x. w" ---
, c. c.
c : <
~
M se Foi4 ?!s mas sem op L./z72 y
N
.e y
=
C DISCLAIMER Tnis is an ' unofficial transcrip cf a meetinc cf the United States Nuclear Reculatory Cc=1ission held on S epte:nber 29, 19 8 2 _ i n ne Cc=nissi~on s offi ces at 1717 H Street, N. W., Wasnincton, D. C.
Tne i
meeting was open to public attendance :nd observation.
This transcrip has not been reviewed, corrected, or edited, and it may contain inaccuracie-Tne transcMpt is intended solely for general informaticnal purpcses.
As provided by 10 CFR 9.103, it is no: part of the formal cr informai record of decision of the matters discussed.
Expressions of opinion in this. transcript do not necessarily reflect final determinations or b eliefs.
No pleading or other paper may be filed wi:n the C =ission in proceedinc. as the result of cr addressed to any, sta smen; or argunent any
' co'ntained herein, axcept as the C:=ission may authori:e.
~
e S
o
+
t.-
N i
e i
1 UNITED STATES. OF AXEEICA 2
NUCLEAR REGULATORY CO MISSICN F
3 4
BRIEFING ON QUALITY ASSURANCE - SECY -8 2-35 2 5
PUBLIC MEETING 6
7 Nuclear Regulatory Commission 8
Room 1130 9
'1717 H Street, N.
W.
10 Washington, D.
C.
11 12 Wednesday, September 29, 1982 13 14 The Commission convened, pursuant to notice,
P-15 a t 3:05 p.m.
16 BEFORE:
17 NUNZIO PALLADINO, Chairman of the Commission VICTOR GILINSKY, Commissioner 18 JOHN AHEARNE, Commissioner THOM AS ROBERTS, Commissioner 19 JAMES ASSELSTINE, Commissioner 20 STAFF AND PRESENTERS SEATED AT COMMISSION TABLE:
21 S.
CHILK R.
PARRISH 22 3.
CUNNINGHAM T.
HARPSTER 23 W.
DIRCNS E. JORDAN 24 R.
VOLLY.ER J.
ZERBE 25 n:Eascu E::: ec ccvusy. isc,
2
- s 1
?ECCEED1E&5 l
2 CHAIREAN PALlADINO:
The meeting vill please 3 come to order.
4 The s.ubject of today's ne.eting is a briefing 5 on quality assurance.
The subject of quality assurance 6 at nuclear power blants is one in whirh the Commission 7 has had great interest and one in which I have'been a particularly in te re ste d since joining the Commission.
9 I believe that many of the quality a ssura nce 10 problems tha t some utilities have faced have been the 11 result of the lack of att,ention, paid to quality 12 assurance by the nanagement orEibizations.
k'e hEve"seen 13 the results of the lack of attention very vividly in 14 certain plants under construction.
I provenents :ust be 15 made both by industry and the N3C to correct 16 inadequacies on the approach to quality assurance.
17 The staff has forwarded to the Cocsissica a is number of initiatives they believe they can help bring 19 about and bring about improvements as a result and ther 20 are here to discuss these initia tives.
21 In the interest of time I have asked the EDO 22 if he-could summarize the position of the staff rather 23 than go through all the slides and using only those i
l 24 slides that you think are absolutely necessary and see l
i 25 if it can't be done maybe in about 10 or at the rest 15 1
I l
t n :E:s: s : : :-.,s : : n w.:.
m
3 i'
t 1 minutes.
I would ask the indulgence of the Co==ission 2 to withhold questions until that is doce.
I would also 3 ask OPE to be prepared"to give a five or seven minute 4 summary of the'ir position so that we can ce t to the 5 questions.
~6 Are there any comments from my fellov 7 Commissoners?
8 C05EISSIONER AHEARNE:
I have one.
9 CHAIFEAN P ALLA DIN 0':
Sure.
10 COM ISSIONER AHEARNE:
In this short summary I 11 would hope that he could start by defining what he means
~
12 by quality assurance and perhaF=4 contrast it wi th-whe t 13 h'e means by quality control.
COMXISSIONE3 GIIINSKY:
If I ran add one more 14 15 point.
16 (Lauchter.)
CO!MISSIONER GILINSKY:
It doesn't count 17 18 because CHAIRMAN PALLADINO:
I know.
They haven't 19 20 sta rted.
21 (Laughter.)
COEEISSIONIE ASEAENE:
It may be they vill 22 23 never get started.
( L aught e r. )
24 COE!!SSIONE? GILINSKY:
There is a statement 25 q~ E E t.
i=c :~ '.G ::'.*n t. v..%:
e i
f 1 somewhere in the presentation about th e responsihility 2 is the licensee's and so on.
I thint. in a certain sense 3 I agree with thit, but' I vo uld like a riear statement of 4 what we think is our responsibility,and what we think is 5 ths licensee's responsibility.
6 CHAIRMAN PALLADINO:
'n' h y don't you take those 7 under consideration, but if they don't cover it to the 8 extent you vould like why don't we come back with
~
9 questions on those points.
10 Any other comments, Jim or Tom?
11 (No response.)
12 CHAIRMAN PALLADINO: ~ RNr d on ' t you preceed, 13 Bill.
14 ER. DIECKS:
Ihe first question, I guess I i
15 rould refer to Enclosure 1 to the paper.
It uses a 16 definition in Appendix E.
But I think the short answer 17 is quality assurance, as ve define it in our progra, is 18 the attemd we have to assure curselves that the plant 19 ess en tially is constructed in the manner that the 20 licensee has proposed that it be constructed in.
21 Now in terms of what quality assurance seans 22 in a note general sense, it really is a program in turn 23 carried out by the licensee to assure that the 24 struttures, systems and ccmponents essentially are 25 constructed in a satisfartory manner and vill perfern in n.:sases =s:c m,s c vn.e. is:.
._m
. _ _ ~ _.......
S' t
1 a satisfactory manner.'
2 Quality assurance includes various other items 3 of which quality control is one.
I think quality 4 control is the first-line inspectic.n to assure that a 5 particul'a'r job has been =erfor:ed right.
Quality 6 assurance is the total program to ensure that the proper 7 T.ethodology and the proper p ccedures and the proper 8 controls have been exercised over the construction of a 9 project.
10 That is a tambling way of how I look at it.
11 Q ua lity control is the first-line at the fabrication
~
12 stage.
Quality assurance is thai,o v e rall program-of.
13 =anage=ent*and quality assurance as ve use it is our
)
14 general program to assure that the licensees have 15 satisf actory quality assuranca pre;ra:s.
16 I don't' knov if somebody else'say vant to jump 17 in on that.
18 MR. VOLLMER:
Could I try one.
My shorthand, 19 Co=missioner Ahearne, vould be that quality assurance is 20 the procedural and managerial activities n e cess ar y to 21 provide a system to see assure and verify that the 22 specifications which are i=portant to quality in a plant 23 have been met.
The quality control vould be the 24 s ea surem en t or verification that specific s;ecification 25 requirements had been net.
Again, quality assurance c :::s:s :s=c: sc c:v:v.*.s c.
.~.m..
6 i
e 1 being procedural and managerial and the quality co,ntrol 2 the act and the process of measuring and verifying that 3 the specifications have been met.
So quality control is 4 s o r 't of a s u b s e.t of the quality a ssura nce a ctivity.
5 CH AIRE AN P ALL A DI?iO :
Why don't we accept that 6 for the time bein; and then you can probe f urther if you 7 have further questions.
8 ER. DIRCKS:
Do you want us to take a crack at 9 the second question?
10 COM ISSIONER GILINSKY:
No, you can just cover 11 it somevhere along the vay.
That is fine with me as 12 long as ve get to it.
24.
13 1511de presen tation. )
14 EE. DIECKS:
I don't knov whether
=y time is
~
15 ticking nov or not, but let ce briefly su==arire.
I 16 think what we have done in this paper has been to 17 essentially pull together in one dorusent a series of 18 initiatives.
Some of them have been ongoing, some of 19 them have been going on for some time, some have been 20 developed at a rather late stage and others are in the 21 formulation stage.
22 We call them a series of initiatives designed n to essentially fulfill what we regard as our agency 24 r es pon sibili ty to assure ourselves or to provide 25 curselves with some confidence that car re; latory r E:s N:E::: c v;:..v.
9 1
5 1 program is being followed by the licensees and at the on'th}requirementsbeing 2 same time ve have kept one eye 3 developed in the Congfess in the authorization bill.
We 4 believe the initiatives we have proposed here vill 5essentiaIly meet not'only our own programmatic needs but
'6 at the sa:e time fulfill the requirements that we think 7 vill be imposed upon the agenry as a result of the 8 passage of the authoriration act.
9 What we had intended to do was to run through 10 the series of initiatives and give you a brief them and demonstrate to the Consission 11 description of -
~
12 t h e various schedules that w e 444a b e e n on.
T:st vas in 13 the series'of slides that ve.provided to the 14 Con nission.
Essentially many of those initiat'.ves you 15 saw the last time ve were here.
I think v e hav e added a 16 f ew and polished up all of th e m I h o pe to make the: more 17 clear and to demonstrate how they fit in the totality of 18 the package.
19 We again have put this thing together with one 20 eye not only on our responsibilities to assure ourselves 21 tha t our regulatory requirements are being followed, but 22 at the same time ve vanted to assure ourselves that 23 vhatever we did in this package of proposals vould not 24 relieve the burden on the licensee.
25 As we mentioned the last time, and I think the u :s:s:., = E:::.: ::. = e.-
E 9
9 1 Concission agreed, the' responsibility to assure the safe 2 construction of tho,se plants, the sitisfactory 3 con stru ctio n of those' plants lies with the licensees.
4 There is nov vay that w e ca n r.e gula.t e in qu ality,
k' e 5 have to rely on their initiatives and their management 6 controls to bring off a soundly constructed plant.
7 We did refer in our paper to the series of 8 actions that 1520 was undertaking and we are building 9 Our program to some extent around the h ope and promise to that INPO vill succeed in its efforts.
I see Admiral 11 k'ilkinson is si t ti n g in the first row there and if the
~
12 question comes up he ran certaf4by describe what-IN?O is 13 doing f ar be tter than ve ca:.in the brief suarary sheet 14 that ve have provided to th e Commission.
15 The initiatives we have are both short ter:
16 dealing wi th the NTG1 pla nts, tid-ter: in dealing with 17 some of the actions tha t we vant to pursue in the 18 development of the progra: and ve have a provision in is there for long-term reviev vhich I think has the basic 20 elements contained in the propcsed authoriration bill.
21 That is a brief overview cf what we have 22 provided the Commission.
If we vent any deeper I would 23 exhaust more than 50 minutes I think in revieving item 24 by item the series of initiatives ve have propcsed to 25 the Commission.
2.:t:sesst:c ms: crv:tsv. sc.
g,
=
1 COMMISSICNER'GILINSKY:
Could I ask, dc you 2 not plan to go over these items?
3 CHAIRMAN PALLADINO:
I had asked for a short 4 presentation because I thought if we vent over the items 5 ve would'never get t'o the questions.
6 COMMISSIONEE GILINSKY:
The questions vould 7 presumably be on the items.
8 CHAIEMAN P AL LA DI N O:
Oh, the questions can be 9 on anything in the whole QA' program.
10.
Unless you think otherwise, I was going to ask 11 OPE to give a summary of their comments on the proposal 12 and then open it up for questic.4s.
13 h?.. ZEEEE:
First.cff, OPE reviewed the SECY I
14 paper and we certainly believe the initia tiva s 15 identified by the staff are'cajor steps forvard as the 16 NEC comes to grips with the quality assurance area.
17 CHAIRMAN.PALLADINC:
Jack, could you speak 18 more into the mike, please.
19 MR. ZERBE:
I would propose to just reviev the 20 summary of our comments of what we recommend that the 21 Commission consider on the subject.
22 One is ve vould prepcse that they consider 23 publishing a policy statement which encompasses the 24 following items:
the importance that the Ccamission 25 still puts on the area of qualiry assurance; an 4
Eh
$hb b
b Y N $*.
,b
1 indication of the Commission's concurrence with or 2 modifications of the staff initiatives as approved 3 vithin the authority of the ED0; and an indication of 4 the* Commission 's approval of the s ta f f to pursue 5 revisions in tne SEC' statutory authority to i=plement a 6 system such as being used by the FAA to extend the 7 quality assurante area.
8 The next item is a number of questions have 9 rome up a b's u t the orga nira tional realignmen t.
The staff 10 has gone quite far in coordinating and co=bining all of 11 the various QA activities in the staff.
However, there
~
12 still are sev2ral areas that sest to be s e p a r a t e -a n d 13 only come up
.o the EDO vhese they go together and there 14 could be some question about whether it is not desirable 15 to have a nice clean line f or all of the CA furctions.
16 COMMISSIONER AHEARNE:
Jack, is that a low-key 17 vay of say that you have a position tha t there should be 1e such an activity?
19 EE. ZERBE:
Well, you know, in a utopian 20 society why a t; or; a cira tion really doesn't matter.
You 21 can get the job done no matter what it is, and with real l
22 people it could possibly be echanced if you 23 00MBI55IONER AHEAENE:
Where do you place that kind *of an or;anization ?
l 24 i
25 MR. ZERBE:
Pardon me?
ALOf:!C'. :::::TP.3 C W (*.Y. A ;.
W.
1 COMMISSIONEP AF.E A ? N E :
Is this where th,at 2 utopia found?
3 (Laughter.)
4 MR. ZEREE:
Nc, no, its real people.
So I 5 vould sa'y th'at I guess ve vculd feel that it might be 6 better to put in a straight line for most of the 7 activities that are in the outfit.
There might be 8 reasons that that can't be done that ve are not aware of.
9 COMMISSIONER GILINSKY:
Since John has broken 10 the ice on asking q ues tion s ---
11 (Laughter.)
12 COMMISSIONER GILINSKEtt --- can I take-you 13 back one item.
f 14 ER. ZEEBE:.
Yes.
15 COMMISSIONE2 GILINSKY:
You urged a policy statement on the Coomission.
Is this something that 16 17 really has an impact?
What vocid a policy statement 18 acccmplish?
19 MR. ZEREE:
Well, I think it would at l ea st 20 express to the people cutside of the FSC that the 21 Co=missioners are 100 percent behind this emphasis on 22 quality.
Certainly people in the industry are going in 23 tha t direction and I think it vould be appropriate that What.has happened so far as a result
~f the SECT paper i
24 25 here is that the EDO has taken a lot of steps and he has i
u:5:::s :t:::-.: ::..: e...:.
t
. -... ~
i 1 put them into effect.
2 Nov I think it would be appropriate that-you 3 people, even though maybe it is not needed, that you 4 people say you.are in favor of those steps so that it 5 vould give emphasis to the outside world, you know, that 6 you continue to support the importance of 2A.
7 Relative to the comments on INPO here ve vould 8 propose, and I think that the staff plans to do this, 9 that when INPO comes up vith their plan on quality 10 assurance that there be a memorandum cf undersranding 11 between INPO and NRC concernin; that so there is no 12 =isunderstanding.
24-13 COMMISSIONER GILISSKY:
Are we clear on who is 14 doing what?
15 ER. ZERBE:
Yes.
k's make sure that we knov 16 vhat they are doing relative to what we are doing and 17 vice versa.
00%EISSIONER GILINSKY:
Do you have any 1a 19 thoughts about where the lir.e ought to be drawn and wha t 20 sort of things are properly in our camp and what sort of 21 things are properly in INFO 's camp?
22 ER. ZERBE:
No, I don't have any thoughts on 23 that right nov.
Relative to these seminars that the staff vas 24 25 pr: posing for senior nanagement frc: the utilities, ve 4.:t scr, :tacc s ::vau.v. :*.c..
12 1 thought it appropriate'that you consider having s 2 Commissioner or Commissioners a ttend th o se, and I would 3 add to that maybe the top.i?C operating manager in the 4 QA area should probably attend, too.
If you are going 5 to have hose people in you should show that y6u have an 6 interest, too.
7
?.e la ti v e to the long-ter: progra=, which we 8 feel is i:portant that the staf f have that there, there 9 are some things tha t we th o ugh t cich t be added that are 10 identified they weren't.
For instance, one could get 11 the impression that all of the QA problems, and maybe
~
12 most of thac are, are only in -(M& a r ea o f e nf o rcec: nt, 13 but while one is looking at.the long-ter situatio in 14 OA they tho u gh t it appropriate that ve also addres; 15 licensing, research and standards.
There are very 16 likely things in those areas that could stand some 17 polishing that haven't been identified.
18 The next items was to' cover and consider the is con tractual aspects of the procurement process.
In a 20 carent ANS conference on quality they identified tha t 21 that is an important area.
Through the contract that a t
22 licensee has with a vendor he, passes on OA requirements and whatever you pass on is what you are going to get.
23 24 So attention should be given to that aspect of the whole i
25 OA activity.
AL:1:!:s :E:0:-*.3 00*.4 v.v.;t.0
~
a 1
Again I mentioned in the SECY paper that you 2 are going to get i lot of feedback on lessons learned 3 from revieving all the lessons that are learned and ve 4 feel that should be facrored into the A NSI standards if 5 appropriate'and I be'lieve there is an intent by the 6 staff to do that.
7 Th en, las tly, on the total pro; rim in the 8 schedule tha t is in the SECY paper, and it extends over 9 several fiscal years, and we thought it was appropriate, to and I suspect that maybe the staff has this in nind, to 11 issue periodic progress reports on how things are going 12 towards meeting those goals th&?iare identified t-hers 13 just so eve rybody doesn't 1pse track of it as you cove 14 downstream.
15 CHAIR!AN PALLADINO:
'd el l, I an sure the 16 Commission has a number of questions.
L have questions 17 in four categories: general, reorganization, designated 1
18 representatives an d long-te rm re vi e w.
Maybe I might 19 start with a couple of my general questions and maybe 20 one question on reorganization.-.Then I am sure others l
l 21 vill have other guestions as well.
22 Under general I vas interested in knoving to 23 vh a t extent you had industry input on this program and 24 vhether you have industry com:ents that have helped ycu 25 or industry co= men ts tha t you think ve cucht to seek.
A';E:<$0s :E:C:r*.G COv:Asv.. 0,
.._._m--__.-
---.eso.-
as
l j
[
1 MR. DIRCKS:
I don't think we have any. formal 2 industry input into this propo sal.
'I think this has 3 been enerated principally from within the staff.
I 4 think ve have~had probably contacts by the industry in 5 rertain'a'rea's and I vould have to let others describe 6 vhat directions those comments vere going.
7 I personally have had several meetings with 8 Den nis 'n'ilkinson on their efforts as well as you and 9 that has been my principal input fro what INPO is to doing, but I ha ven 't ha d any romment on this particulcr 11 parkage of initiatives.
12 COEMISSIONER AHEARNI::L3ill, should I --
13 interpret that those =eetines, vere those ones in which 14 you vere trying to understand what INPO vas doing or 15 vere they ones in which you tried to keep INFO abreast 16 of what you' vere proposing?
17 MR. DIRCKS:
I think it is the former, trying 18 to understand what they were dcing.
19 Ed Jordan might want to talk about it.
20 ER. JORDAN:
We have had discussions with IN?O 21 and with individuals f rom industry about the various 22 initiatives which I am sure helped form the vay they came out, but the:e was no formal comment, not a ct u all'y 23 24 a transmittal or a package requesting a formal response.
C05MISSIONER GILINSKY:
Could I a sk you, is a 25 a
N
. A,Y
- '. C.
f 1 fundamental assumption here that our requirements ade 2 basically sound and there is sufficient guidance on hov
,3 to carry them out o r wh.a t is needed is more attention?
'4 ER. J3RDAH:
U; to the long-term reviev ve 5 vere making that assumption and I personally believe 6 that, that essentially the guidance is there and it is 7 sound.
Whether it is as good as it can be, I don't I
l 8 think it is.
So it would be feeding the lessons ve have l
I l
9 learned out of this concentr.ated effort over the next I
i 10 year back into the standards.
11 COMMISSIONER GIIINSKY:
Is that the sense you
~
12 get from the people that y o u d arl. v it h in t h e in d u s t-r y,
13 that they feel, c.all differ,e,nces aside, that the
?
f 14 requirements are b a sica lly sound, because one hears a
.q 15 lot of complaints about the effort in carrying these I
16 requirements?
1 17 KR. JORDAN:
We are feeding back the industry i
18 comments there that th e require,ments are vide and deep 19 and_oftentimes confusing in tercs of what applies to a 20 particular case and how one should interpret the 21 requirement. So clarity can be lent in that kind of 22 situation.
23 EE. DIECKS:
You kncv, one test, and you might 24 get into this a little late r on, is when ISPO developed 25 their criteria on which :: base their evaluations of i,
e ALCEE5CN EEPCM;NG COM W. INO.
___ _____ __- _- _._AM M A R NM A_ AVE. B W.
WAh M O T % ** O 20C16 IROR!a g ay,
y-1 quality abou't these plants, one thing ve did get,into in 2 one meeting was did these criteria vary creatly from 3 vhat we vara requiring ~, because if industry and IN?O 4 censrated a whole series of requirements and criteria
~
5 completel'y away, going in another direction from our 6 requirements, then ve all should step back and vorry a 7 bit.
%aybe ve are asking for too much or maybe not the 8 right items.
But I think if you look at th e criteria 9 that have been developed, an'd Dennis could explain them 10 later on, I don't think they have gone off too much in a 11 dif f erent direction from what we are asking for.
12 CHAIRMAN PALLADINO:. 1(11, I was thinking of a number of 13 the fact that we seem to be,1: posing i
14 requirements that I think are going to be rather costly, 15 and I am not saying that we shouldn't imp;se them, but 16 ve might get some enlightenment by discussion with 17 industry people, and I was vondering to what extent you 18 had gotten such enlightenment? -
19 ER. DIRCKS:
That might be the next step.
If 20 y ou talk about a policy paper or a policy statement, you 21 might vant to send it out f or comment to see the 22 reaction to it.
CHAIRMAN PALLADINO:
Well, a related 23 guastion.
Some of this looks to me like significant 24 25 backfitting and I think one place in your slides you n.:s:scu RE:c:.
G c:vn
- sc.
.......~.
~.... u. -,.,
18 a
1 even used the vord " ba ck fi t tin g. "
2 COM EISSION ER GILINSKY:
He said they weren 't 3 backfitting.
4 CHAIEMAN PALLADINO:
I kn.ov, but I used it.
5 (Laughter.)
6 CHAI? AN PALLADI!'O:
Ey question is did this
~
7 proposal or this series of initiatives go thrcugh the 8 CRGR and, if not, why not?
9 MR. DIRCKS:
Well' CSG3 is an ins titution that 10 I use to advise ne' on certain areas.
I don't use it 11 formally on.everything.
I ce r.t.a in ly d i s c u s s th e s.e.
12 matters with my Deputy, Vic St'eiis, who has a
~
~
~~
13 relationsh'ip to the CEGR.
F 14 (Laughter.)
15 MR. DIRCK5:
I really didn't icok on these 16 initiatives as for:al regulatory requirenents in th e 17 sen se that some of.the other requirements that the'CEGE 18 looks at.
19 CHAIR AN PALLADINO:
Yes, I agree, not 20 everyone is in the same category.
21 KE. DIECKS:
I looked on these ar e = ore of an 22 approach to a problem and to deal with reinforcing some 23 of the gaps that we have had in our programs.
24 COMMIESIONER ROBERTS:
Excuse me.
Ihis 25 designated representative analogous to the syste:
4 AL;E ASON P E:C:" G 00'.*F iNY.
- 0.
YV 1 employed by the IAA, that is certainly a potentia 1 2 regulation.
3
- 33. DIRCKS:
Now all that is in this 4 initiative is an indication it is something ve vould 5 lik e t o 't ak e~ a look at.
It certainly doesn't commit us 6 to doing tha t.
7 COEXISSIONER GILINSKY:
I thought you vere 8 asking f or a green light to draft the issue.
9 MR. DIRCKS:
No, I think it is more of a green 10 lig ht to get some more ansvers to more questions that 11 are going to be developed.
We are not proposing this as 12 a let's go and do it type of thig,g, but let 's gaim mor 13 inf orma tion.
14 COEEISSIONER ROSERTS:
That is not the way i
15 r ea d it from Jack's paper.
Sorry, different 16 interpre ta tion.
17 ER. DIRCKS:
Well, it is.
My view is that it is is.
19 ER. ZERSE:
We recognired that there was going 20 t o be a separate paper written on this subject.
You 21 know, there are some certain aspects of that approach 22 that we might not be particularly careful, you know, but 23 there v'as going to be another round of that through this separate paper.
24 25
- 53. DIRCKS:
I think wha t we are trying to do at:E:!:N:E:C:,sG ::'.a:Asv N.
mm...--.s
<m.--.,
--....,..pg;...;,.
o
20 1 is gather up a series of thin;s here to get a reaction 2 from the Co= mission to see wh ether ve should pursue 3 then.
The FAA approach was 4'
COM5ISSION ER AHE AESI:
Can I interrupt you 5 just a moment?
6 EE. DIRCKS:
Yes.
7-
'COMEISSIONEE AREAENE:
Isn't it correct that E the paper you sent up said here are a list of things I 9 have already done for your 1nformation, plus here is to something ve are asking the Commissien to act on, and 11 that action is to tell you that, yes, you can look
~.
12 f urther into the designated rer=asentative?
l 13 ER. DIRCKS:
Yes,,right.
I~
CHAIREAN P.ALLADINO:
Well, since a number of i
14 15 these ite:s have been done and you are asking for 16 actions such as independent design revievs, hov-have 17 these been forwarded or imposed on the licensees, by 18 letter or what?
19 ER. DIRCKS:
There is a series of things.
I 20 think the NTOL area and then others.
Let me ask Dick to 21 go in to that, Dick Vollmer.
COMMISSIONER GILINSKY:
Could you just say 22 23 vhat has been done and what there is to do?
MR. DIECKS:
In fact, there'is a slide you may 24 25 van t to refer to.
u.: E t s : E: c e.r*.s c e u P m.iN O.
y 1
C.OX.5ISSICNIR, GIIINSKY :
Well, we got denied 2 the slide.
3 (Laughter.).
~
4 CHAIEMAN P ALL AD!NO:
.No, I didn't deny the 5 slides. -I just tried to limit it to'see if you could 6 giv es us a su: mary in 10 minutes.
7 ER. VOLLMER:
Well, on slide 9,
"Heasures At 8 Near-Term Operating License Facilities," ve hav e asked 9 lir ensees f o r th eir self-e valua tions.
Again, I think at to the last committee meeting it was characterized as being 11 a mechanis: for getting th e utility to attest to the 12 quality of desi;n and construrtian of his plant and to 13 sta te that it is in accordap.ce with the application.
p 14 k'h e r ea s before that I think th a t burden was taken on 15 : ore by the staff than the utility.
It indicated we 16 vere lookin g for a mangemen t official, a CEO or 17 vha tever, to certify that the plant design and 18 construction was in accordance.vith the application.
19 We have held so f a r NTOL meetings vith 20 applicants wherein they gave us a document and a 21 discussion about why they felt that the management 22 controls that they applied, the qualtity assurance and 23 the quality control, was ad equate to meet the 24 Commission's regula tions and assure th a t the facility
~
i 25 was designed and constructed in accordance with the AL ER$CN ~EFC ATWG COM 1 *. E * *.' O.
wm *.wn:. t
.a.-
.ac A C ;NMCN O"
- 4
- l!!.a.
4!
22
.9 e
1 application-.
2 C0EMISSIONE3 GIi1NSKY:
Now is this a useful 3 process?
4 MR. VOL L Y.E R:
Well, it started out to be a 5 very useful ~ process, out I think as it vent on and more 6 people understood pernaps what we vanted to hear and it 7 berane somewhat repetiticus S
COMMISSIONES GILINSKY:
I will tell you why I 9 ask.
We have had =anagement from some of the places 10 that we have had the mest problems with_ cor.e in here and 11 tell us that things vere really pretty good.
This is
-~
12 usef ul if it leads tc. some retritking and people-13 addressing their pro: Lens.
14 MR. VOLLMET:
Ihe regions were involved.
We 15 were aware of design problems that they had and we vere 16 aware of construction and implimentation. problems from 17 the regions.
So ve did probe these things at th e 18 meeting to try to get a feeling if they had taken good 19 mangement response at all levels within the utility 20 organization to deal sith these.
So it wa s a perception 21 that we would have if they were on top of the CA 22 initiatives.
COMMISSIONER AREARNE:
'a* h e n y o u s a y that you 23 24 have asked them to do a self-evaluation, vas this in any 25 vay a structured evaluation or was it more a request to l
A L C 12.$ C N 210C E 7:N O C O' N'e' ih 0.
23 t thes do an evaluation and then come back in and tell us 2 whether or not you agree the plant was built correctly?
3 ER. YOLLMER:
I think it is basically the 4 latter, that we asked them to gome.in and try to give us 5 the util'ity's rationale for feeling that the plant was
~
~
6 designed and~ constructed correctly.
7 COMEI55IONER AEEARNE:
I vocid gu ess-t hat if I 8 contrast that with at least what I have seen of the INPO 9 self-evaluation, which is a 'cuch more structured 10 requirem ent th at the utility go through very specific 11 steps and justify a number of itecs, I would offhand 12 g ue ss that this is not going t cacrod uce much in the var 13 of usef ul in put.
14 ER. DIRCKS:
I thins thou;h you have got to 1
15 look where ve vere before ve started any of this, and I 16 think if there was one complaint we heard was there was 17 a lack of canagment attention to the QA program.
Many a 18 firm would delegate this off to a contractor er to a 19 supplier or to an architect engineer.
There was a gap 20 between the attention that the Chief Executive Officer l
21 Vas giving to the problem and what was actually 22 happening out there.
Ihis in itself probably vill not be the answer 23 24 to anything except it is a step to try to get the top 25 sanagement of the firm to commit the selves to the 1
f y
AL: !:$
- t. :E :::
- a. 0 c : a.
- v.*
- . C.
7 W
1 problem.
In and of itself I think it is a very s:all
~
2 step.
Again, if we are saying that there is a gap 3 between'what mana;ement shouli be doin; and wha t they 4'are actually doing, maybe this is an attempt to drag 5 them int'o th~is.
6 COMMISSIONER AREARNE:
k' h a t have you done vith 7 the products?
It says 11 vere completed this conth.
8 Were there any products produred previously several 9 months ago that you could look at and you could say what 10 you have done them?
11 ER. YOLLKER:
All of the products, at least on 12 the plants, Susquehanna, San OG66ce, La Salle and-a -
13 couple of others have been reviewed by the staff, both 14 by ourselves. and the regions, NRR, the regions and ICE, 15 and I think the conclusions vere reflected in our safety 16 evalation reports for those facilities.
For whatever 17 reasons that we had at the time, we feel that the plants la have been ad equately managed by. the utility fro: a OA 19 point of vieV in design and construction.
How in these meetings it was clear from the 20 21 beginning that few, if any, of the licensees had put any 22 ef f ort into looking at the procedural or technical 23 d e sig n 'a spe c ts.
They all had QA programs and we knov 24 vhat* the requirements a re there, but dettin; into when 25 ve asked a question have you, yourself, done any design AL::ERSCN *E.:CRi;*iG COY A N f. NO.
~- - m
25
~
1 verifica tion or ha s all of your design verificatien been 2 given to the cognizanre of yoc: contractors, your NSSE 3 and your A/E, the ansvers were I think alcest 4 universtily yes.
That vic their jo.b and we ga ve them 5 t ha t' del'eg a t ed authority and we looked at' it no further.
6 Ve felt that based On th e problem s tha t ve had 7 seen with certain plants that we were unconfortable that
~
8 the design authority was delegated without any 9 independent look it it and I think f rca tha t grev eur 10 request to a number of plants that we feel we need sene 11 additional look, an independent look, if yo u vill, by 12 somebody who was technically qnxtified and had no 13 particular* dealings with thp. project itself, that vould r
14 take a part of it and say ve have looked it it 15 procedurally, we have looked at the interf aces and we 16 looked at it technically, and fron what we have looked 17 at we think the design process is acceptable, a 18 thi rd -pa r ty look, if you vill.-
19 We have had seven who have agreed to do 20 third-party looks.
We have had three utilities who have 21 come in with third-party looks.
They preposed them at 22 the time of the management meeting.
Two of those I 23 vould characterize as being independent design reviews
^
24 of a selected portion of the facility.
CHAIEhAN PALLADINO:
Incidentally, is that 25 e
A.0 E R S O N
- E
- C *
- N G 0 0 'F '*.
l' W
l l
j e
(.
l 1 What you maan by independent design reviev, a reviev of 2 one of the selected systens?
l-
[
3 ER. VOLL! err I would characterire it in the 4 brohdest sense.as a review of the proced ural and 5 technica1 ad'equacy o'f the design process by picking out
~
j 6 a design exa:Ple ind looking at it.
Ihere have been 7 some other things proposed.
In one particular~ plant the 8 licensee has proposed doing something whirh I would not 9 characterize as an independent design reviev.
In my own
~
10 view, this particular utility ve think has had a good 11 record of quality assuranre.
He has a number of nuclear
~
12 plants and it is my vie'v ve prCSsbly von't ask hi to do i
13 any : ore than what he is proposing to do.
14 CHAIE!AN PALLADINO:
Dick, how is this laid on 15 the utility?
Do they get a letter saying do a 16 self-evaluation according to this and if you meet 17 certain criteria you don't have to do an independent 18 d esign review or if you don't pass you will have to de 19 an independent design review?
How is this all set forth 20 to the utilities ?
Is it by letter or by order?
21 ER. V3LLy.EE.
It is usually in something which 22 summarires the management meeting that ve had with 23 them.
After the nanage:ent meetin;, as I indicated, which is usually attended by the NRR Division Directors, 24 25 the NRR Office Director and top ICE regions 1 e
e$
e
,9
27 1 representatives ---
2 CHAIRMAN PALLADIFC:
But is th e re a formal 3 follov-up?
4 MR. VOLLMEE:
There is a follow-up.
Usually 5 after that meeting we cet down to discuss whether or not 6 ve think they have prasented us in this package with 7 enough information to gives us assurance of th e design 8 and construction process.
Usually what is lacking is 9 design.
So ve discuss how can we get more assurance 10 that the design process is procedurally and technically 11 adequate?
So ve ;et into, you knov, what are you going 12 to give us, if you vill, and ii_gou call that tvisting 13 their air, I guess then we,tvisted their arm.
14 CHAIRMAN PALLADINC:
Eeally I am not finding 15 f a ult wi th the initiatives.
I a: concerned about how ve is get the: forth, are they require =ents and are they set 17 forth in a formal nanner?
18 MR. VOLLMEE:
They are indeed set forth in 19 formal manner.
As a result of this meeting ve then send 20 t h a n a letter usus11y in the context as a follov-up to 21 that neeting saying we understand that there vill be an 22 independent desigc review of this particular area which 23 ve usually discuss, or are you going to propose one, and 24 they. Vill select COMMISSIONIE GILI.iSXY:
At vhar level in our
- s 4.
g::
.:t: :
.G :
'.:a,v x
25 1 organization is that done?
2 MR. V0lLMEE:
At Mr. Denton's level.
He has 3 been involved I think in all of these manage:ent 4' mee tin s, pe rh aps with the exreptica cf one.
Sometir.es 5 at th e
.e etin; they c:me in and say for these reasons
~
6 here is a design aspect which centained a let of 7 interfaces or there was a big design change made during 8 the life of the project and this is an area which might 9 have the highest potential to h a ve design deficiencies.
10 We vill select that and take a look at it in the desi;n 11 process.
12 In some cases her sFfA+e vill go en back'and 13 think about it, think ab ut.a centracter to do et: vork 14 and then they would send in a proposal to us.
We voeld 15 review that, ICE and the recicas vould see it and ve 16 vould v ri te back our acceptance of that propesal.
Then 17 ther vould do the work, submit the review to us and it 18 vould be written up in the SER'-s.
Nov it has ru: quite 19 a broad variety in terms of scope and depth of the 20 r ev iews.
I think the mest d'etailed has bee: San Onofre 21 and there have been sc=e down to a rather mcdest 22 selection of one very local design vhirh rovered 23 interfaces dealing with the NSSS vendor and the 24 architect engineer, but still a dequa te to show that 25 interfaces, procedural and technical mattets were dealt n.:sases :s::::,c c vns-s :.
,,....,--nr.
- n-
29 a
1 vith appropriately.
2 Again also whoever does this independen t 3 design review has been' asked by the utility to make the 4'sta'ement that it is their view tha.t the design process t
~
5 does meet' the require:ents of the application and things 6 like that, again a third-party reviev, if you vill.
7 CHAIREAN PALLADINO:
' Jell, I guess what I 8 really was seeking is that there is some assurance that 9 ve vere settin; forth these* requirements in a formal way 10 a n d that we knew that they were set forth and the 11 utility knev vhat it was that it was supposed to do.
I 12 was a little unsure on the ind&phadent design reviev 13 because it'is not clear to ;e that they were all 14 required to do it and I a: not clear on what the is criteria are for when you do it and when you don't do it 16 and hov deeply you should go.
0055ISSIONER GILINSXY:
'.' e ll, it sounds like 17 18 they are exercising their j udgaent a nd that the senior 19 people are deciding on the basis of the facts in the 20 case.
21 ER. DIROKS:
I think design Q A is already 22 required under their regulations.
What you are doing is 23 trying to issure tha t they have met the regulations.
Is 24 that.right?
25 ER. VOLLMER:
Design OA is indeed required.
O Y,
kg
, hp f 4 fN hp 6
w
r 30 l,
a e
1 Whether or det the design proress has met the 2 requirements in terms of in terf ace control and
~
3 procedural controls is part of this exercise.
- Indeed, 4 it is done and.it has run the gamut.
It is decided on a
~
5 case-by-case' basis and I guess it is decided and depends 6 on our judgment of how we view the activities 7 involvement in that, the experience with the NSSS and s the A/E and so on.
Is truly nothing that I could pull 9 out a document and say this*is what we are handing them 10 all and go through it that way.
11 CHAIRMAN P ALL ADINO:
No, but you are handing
~
l 12 them something.
- a.
I.
13 ME. V3LLMER:
We do document the precise ll
[
14 agreements and they come in with a prerise program plan l
15 and we do acknowledge our agreement with that scope of l
16 vork, the procedural controls that they vish to apply to i
17 t h a t and tha t is all part of the record, yes, sir.
i 18 CHAIRMAN PALLADINO:
7 ell, that covers my i
19 general questions.
Maybe I ought to allow somebody else i
20 to question and I will piggyback on their questions with 21 rega d to other topies.
22 Vic, do you have specific questions you vould 23 like to address?
24 COMMISSIONER GILINSKY:
Could you tell as hov 25 ve assure ourselves in the course of revieving a license gC E: $ C N S E
- C a P*. 3 0 *. '.e s u.
- J. 0, L
1 1 application that a utility has a satisfactory quality
[
l L
2 assurance program and why do ve need to do more than our 3 standard reviev?
4 ER. V0LLMER:
I.vould hav.e to speak to the 5 program 5atic' aspects and then turn it over to ICE for i
6 the 1:plementation aspects.
7 The pro;ramma tic review is not ;a rticula rly 8 sophisticated in that what we are looking for is a 9 licensee commitment and explanation of how he vill f rom to a management point of view and from a procedural and 11 organizational point of viev implement the 18 criteria
~
12 and how he vill implement the.iatustry standards which 13 are subsets of the 18 criteria.
?
COMMISSIONER GILINSKY:
And this is at what 14 15 point?
16 ER. YOLLMER:
This is at the application 17 review on a CP or an OL.
So de meet with their QA 18 people and their licensing people.
k*e read their 19 com mitments, their response, if you vill, to the 20 requirements of the standard review plan.
OOMMISSIONER GILINSKY:
Let's see, if I :ay 21 22 interrupt you, at the OL stage they would have an 23 organira tion in place presumably.
MR. V3LLMER:
Well, yes.
It depends.
At the 24 25 OL stage tney have s different type cf orga nira tion l
u: :::s = sect sc ::vem. m:.
32 1 because at the OL stage the licensee is responsible in 2 large part for design, construction, operation and the 3 whole bit.
At the CP stage they usually delegate to the 4' architect / engineer and NSSS the activities of dealing 5 with designing and building the plant.
So at the OL
~
6 stage really the licensee is responsible for more 7 activities under Appendix 3 because a y modification 8 they made and many maintenance that is safety related 9 all vould be under Appendix 3 requirements.
10 So sgnin at the application sta;e ve review it how he vill carry out these activities and what he has 12 rommitted to in tarts of reguliYsty guides and ANSI-13 s'tandards which are endorsed.by those.
At that point in 14 time ve have a program docutent which ICI then vould r
15 look at to see that the 1:plementing procedures at the 16 facility either at operation or construction carry out 17 the promisas ma de by that program document.
18 "0EYISSIONIE GILINSKY.:
But somevhere that is process broke down, and it seems to me if we understood 20 better where it broke down ve vould understand better 21 how to fix it up.
22 MR. VOLLMER:
It is my view that the breakdown occurs ' prima rily with the actuai carrying out of the 23 24 procedures that are developed based on the program 25 document.
In other vords, there is a progra document n:suc 4 :secam s ::. w...sc.
33
+
a 1 and then you go out toia site and there is a OA qan ual 2 that is rather large and volu:inous but contains 3 procedures telling hov each vork operation should be 4' conducted, what,the inspection ;oin.ts are, what the 5 quality'chec'ks are and so on.
6 I think it is at thst point that the lack of 7 carrying-out those procedural aspects is in large part 8 where the breakdowns have occurred.
9 COEMISSIONER GILINSKY:
But sonehow we didn't 10 detect the fact that in carrying out the system wasn't 11 as good as it var supposed to be.
~-
12 MR. VOLLMER:
I don't:Like to pass the-back, 13 but that is not in my area here.
I (Laughter.)
14 15 00%MISSIONER AHEARNE:
You tre saying as far (Simulaneous conversations -
16 as the NRR review 17 Inaudible ).
18 COEXISSIONER GILINSKY You don 't have to anyone berause there is enough blame for 19 blane it on 20 everybody here, and on this side of the table as well, 21 but I think ve need to understand.
22 ER. Y3LL!ER:
I think if you look at the 23 com:itments that they have in the licensing documents, 24 and I don't think, even looking back in retrospect, and
~
~
25 ve have had some studies and the Sandia study and so on, AL;!:t:s
- E*
- *. c:vwn, :N,
34 1 that we can' fault what they have committed to do, but 2 doing it has been another thing.
3 "OMy.ISSIONER GILINSKY Eut still somehow they 4 didh't carry away a sense of what they were supposed to 5 do or a commitment to it or va didn't impart that.
6 Something vasn't working.
7 MR. VOLLEER:
It could be.
P erhaps in sor.e 8 cases it was a paper exercise, that could be, without 9 real commitment by the licensee.
10 ER. DIROKS:
I think you have hit on the 11 problem.
First of all, I.think.. the difficulty t o. _
12 understand is why the managec.e694tf the corporations 13 have not been concerned abou+ the quality of the
'i b
14 workmanship they are gettin; in the ;lant.
Ihe second 1
15 problem was did we have an adequate program to pick up 16 wh e re those deficiencies were occurring ?
17 Ihe difficulty is if you have a managemen:
18 that is overwhelmed by other priorities and is giving 19 second shrift to the OA problem.
As I said at the 20 beginning, it is very difficult to regulate in good 21 moti ations.
CO5NISSIONER GILINSKY:
'a' e ll, I a;ree with 22 23 that up to a point, and I am not one to let these guys-24 get off the hook.
But at the same time if we vere 25 standing there and saying, vait a ni use, ycu don't cet 4,:eu:s :p:r-.s ::vn.. m:
35 1 by unless you have got a better program ---
-2 COMMISSIONER AHEARNE:
I think his description 3 that the other parties were interfering doesn't just 4 apply to the licensee.
5 CdMMISSIONER ASSELSIINE:
I think that is true.
6 COMMISSIONER GILINSXY:
Well, what I am 7 getting at here is'the problem that we haven't been 6 enforcing what we should be enf orcin g; in other vords, 9 ve are looking for all these initiatives and seminars 10 and talking to labor unions and a lot of other things.
11 Ihe fundamental probler. that we have got a set of been ebforced.
12 requirements that haven't c
13 EMAIRMAN PALLADIND; As a ma tter of f act, I 14 cather, as you say in your paper, part of the problem is r
15 the failure of NRC progra:s to recognize the extent and 16 the nature of the breakdowns.
17 MR. DIRCKS:
And it is a varied pattern.
I 18 mean there are some facilities out there with management i~
19 dedicated and you don't have these problems.
Others 20 wh e re there is a different set of priorities vill have J
r i
21 massive problems.
We have applied a progra m across the 22 board and w e haven't picked it up.
I 23 I think Ed could go into it further, but I l
24 think there is no question in anyone's mind that given the resources ve have applied to it over the years and 25 j.
1 i
A.:E:50s. !:c AT:ss ::ve m, sc.
w
~_w--
mm.
t
36 1 given the massiveness of the ac tivities out there, yes, 2 ve missed it.
3 COMMISSIONER GILINSKY:
let me push this a
~
4 little further..
When ve inspect, what is it that we 5 inspect for?
In other vord s, hov far do ve go in 6 rhecking out to make sure there really is an 7 organization in place that can carry out a good quality S assurance program and that can oversee the rest of the 9 vork and adequately audit it'and so on?
What is the j
10 nature of our inspection?
11 ME. JOEDAN:
The insp.ection program for.a_
12 utility that had just gotten a#E$bstruction pernii,*
13 l'e t's sa y, ' bark a number of years ago was exactly that, L
14 to' determine whether-the utility had adequate personnel 15 and had assigned personnel with the right qualifications 16 to perf orm the tasks.
17 COMKISSIONER GILINSKT:
Fould they be in place 18 a t that point or their organira' tion?
19 5R. JORDAN:
It vould be being developed at 20 tha t point.
So it is a process that grevs and grows.
I 21 guess one vould have to say that the numbers of people 22 and the qualifications of people have steadily improved 23 over the years.
I guess one of the things we see right 24 nov in conparing the numbers of personnel at a given 25 renstrurtion site that tre sperifirally in the quality AL';EASCN RE CE*:N G CC'.t
- ANv IN O,
37 1 assurance area is that the numbers are much larger today 2 than they vere two, five or seven years ago.
So that 3 the emphasis has increased and the NRC's viev of what is 4'ade*quate has perhaps changed in tha.t same vay.
~
~
5 C0E5ISSIGHER GILINSKY:
Do we have some 6 standards or requirements or positions that at a certain 7 stage in construction the organiration has ;;t to be cp 8 to some level for you to go on with your construction or 9 is it less formal than that?
I will tell you vhat I an 10 getting to.
I wonder whether ve ought not to take a 11 more formal approach toward qualifying the quality 12 assurance organirations which.r e ll seem to agree are 13 the key to*:aking sure that. things g et d one right, set a N
14 whole set of proredures and ad:inistrative con trols and 15 so on, the purpose of which is to catch nistakes or, 16 looking at it the other way, ake sure things get done 17 in accordance with. the specifications?
18 F.R. JORDANS The staff understands that one of 19 the basic problems was, and this is nov retrospect, that 20 in the contractual arrangements that vere nade by the 21 utilities with thair suppliers and with the 22 a rchitect/engineerin g firms they did not e: body the 23 quality assurance elements in the: so that they vere 24 looking for a completed article but not foc a 25 hig h-quality conpleted article.
g:s:ses ats:e.s c:.9asv,s e.
.__..m
38 1
CHAIRMAN'PALLADINO:
There are steps being 2 taken to change that situation.
3 P.E. JDRDAN:
That is one of the elements 4 within the set,of initiatives, y e s.-
The contracts are 5 all in plara nov.
There are no new contra:ts being 6 si;ned for new plants being constructed, but in the 7 quality im prov em en t progran that we are urging the 8 utilities to adopt that would be one of the necessary 9 ing redients for modificaticns, for instance, or 10 subsequent work that the actual contrirt f o r tha t work 11 would ore strongly embody'the-quality. assurance..
12 principles and that it beconV5fhdtothecontraEtodand to the arcbitect/ engineer.
13 t
14 COMMISSIONER GILINSKY:
Vell, to a large 15 extent I think that was the sense of what Bill DircP.s 16 was saying.
We depend on industry to check up on 17 themselves.
There.just aren't enough people here to 18 Watch over all the projects in 'the country.
Now it tg seems to me what we ought to be doing is making sure 20 tha t tha t checking system is in place and is adequate to 21 do the job.
22 Now do We say at any point that yes, this 23 quality assurance system is adequate to proceed to the next' stage of construction in a f o rr.a1 vay, and, if we 24 25 den 't, it seer.s to e that ve cucht to if this is an u.: Esten atac am.c c:'..: e.v. a,c.
m
3?
1 essential an element as ve all say it is and I believe 2 it is.
3 ER. JORDA3:
Insofar as it bein; a held point, 4 I don 't think we could say th a t th s t occurs.
5 COMMISSIONER GILINSKY:
Well, perhaps ve ought 6 to be gettin; note formal abcut that.
I :ean that is 7 the central element.
There is a quality assurance 8 organization that is there to check and double check to s cake sure that a plant is built in accordance with 10 intentions.
11 ER. JORDAN:
I am not arguing with you, but 12 that is not really the problenC6 hat we are faced vith 13 n o w'.
The plants are at various sta;es Of nstruction 14 already and the contracts are let.
So nov ve are having 15 to look at how do ve pick up f rom here.
COMMISSION ER GILINSKY :
I kncv, but, you knov, 16 17 that can be turned around.
Your cc::ents i: one of the 18 papers is that the key problem'is tan;ement attention at is the outset of the project.
Well, it turns cut we are 20 passed the outset of the project in nost of them.
21 ER. JORDAN:
We cet their attention.
CHAIRMAN PALLADINO:
We had to ge t their 22 23 attentien in the tidiand project.
24 MR. JORDAN:
That is right.
25
- 13. DIRCKS:
I though t there was a requirement n:cerer. : race
.3 : " e.-
1 41 1 recognition that there is a variation in th e q uality of 2 the personnel that,is out there.
We have run across it 3 in a couple of th'e bad example plants, and I think that 4 is the basis for your proposal.and your initia tive in 5 here to do something more about the qualification and 6 certification of QA personnel.
7 COMMIESIONER AHIAENI.
Could I ask Ed a little 8 bit scre about something that Vic was folleving on.
9 What do you inspect against 'on the quality assurance?
10 let say you have a pla n t that is in the :iddle of 11 CO n stru ctio n.
What would your inspertors be looking for
~
12 vith respect to the quality ac60bance or;anization?' Ey 13 sense from reading the reports is r. ore that you question 14 the quality assurance cr;aniratica se a seccnd step.
15 When you find problems in the construction, then the NEC 16 tends to ask well why were those problems net uncovered 17 and why didn't the quality assurance organization catch 18 it, and then it says in a secoddary questiening that you 19 turn to looking at the quality assurance organiration.
20 Is that incorrect?
21 MR. J3RDAN:
Etybe in degree.
Ihere are 22 inspection procedures dealing with the quality assurance 23 system itself and then inspection proredure s dealing 24 vith*the artions, the concrete pour and the veld fro:
25 which one then derives v.. ether the quality program is l
1 Ai:E: SON !:C :
- N G C
?.' 8 A '.* 'hC
40 1 to have a 25 organiration and you do inspect to see if 2 it exists and the numbers of it and the reporting 3 requirements and so on.
Do y 2 vant to get into that 4 aspect?
I l
5 ER. VOLLEEE:
The ansver to that is certainly 6 yes.
I think Commissioner Gilinsky asked de ve look at
~
7 nu:bers.
~4e look at qualifications of inspectors and 8 things like that, but we don't have criteria, to my 9 knowledge.
10 C05EISSIONER ROBERTS:
And I think that would 11 be highly impro_per.
The,numbeE of people means
' CM-12 nothin;.
It is the quality.
'OEEISSIONIE GILIKSKY
'a'h o s a id numbers?
C I-13 IDMMISSIONER ROBERTS:
You vere mentioning 4
14 15 num bers a minute ago.
COEEISSIONER GILINSKY:
I visn't mentioning l
1e 17 num bers.
COEMISSIONER ROBERT 5i I misinterpreted Whit 18 19 you said.
I am saying that the numbers of people a re 20 not significant.
COMMI5510 NEE GILINSKY:
Eut I do think that 21 22 there are a set of standards that sn organirstion of 23 this sort has got to meet and you have get to be assured 24 that'it is adequate to the job.
25 MR. DIROKS:
I think there has been a f db
,5 bh, k f-o i-.
43 a
1 just saying that if-they do it we would be pleaset and 2 ve would help them if they vanted to pursue it.
You are 3 right.
4 I think the greitest incentive to all this, 5 and we are seeing it,-and I think,the industry is i
6 turning around berause thsy are seeing what it costs 7 them to have a major proble: in QA, and if there is a anything that is going to turn this thing arcund it is 4
9 the dollars and cents and balance' sheet evidence that 10 comes in.
A couple of examp1'es of fir:s spending a
j 11 couple of hundred million,.delltes to rework a plant,is lihEof attention cui th'ere 12 plenty of incentive to get a 13 t'o correct the problem.
p 14 C0%MISSIONER GILINSXY:
Let =e du st ask just 15 to sum up, do you have any reaction to the notion o.f a 16 : ore formal certification of a utility's quaEity 17 assurance program?.
18 00EMISSIONER AhEARNE:
You mean a t various 19 stages.
20 COMMISSIONER GIiINSXY:
Well, it sounds like 21 it vould have to have various stages to it because the 22 program gr:vs the course of construction.
23 3R. DIRCKS:
Well, we do have something here 24 about the 2ualification f personnel.
This is something 25 that we have an initiative in here on getting sort of a adit,$0N 8 E
- C E T:*.3 0 v 8 A'.'
P. O.
42 i
1 vorking.
So there are both pieces.
2 COMMISSIONER AHEARNE:
Are"the former though 3 ones which tend to be-in that 50 percent or so of 4 inspection modu.les that aren't,able to recover?
5 ER'. JORDAN:
In some cases they have not
. 6 been.
That is cofrect.
7 COE5ISSIONER GILINSKY:
Let ne add a comnent 8 to my earlier one about what I thought our fundamental 9 job was and what we ought to stick to principally.
Some 10 o f this parkage deals with various kinds of exhortations 11 regarding th e m an g em en ts,a nd t.ie unions and worke.rs,and
~
12 s o on.
It seems to me a lot or-that is properly ~1 eft to 13 5dmiral Vilkinson and INPO.
That is something they are 14 good at and I think can be left to them.
15 We ought to be concentrating on our basic 16 responsibilities which is assuring that there is a 17 certain standard that is met.
If va are fairly fir:
18 about it, then they vill be carrying out their 19 self-evaluations and having seminars.
20 ER. DIRCKS:
Well, I agree.
I think that was 21 one of the changes we made since the last me orable 22 visit we had on this subject of QA.
We have taken that
' hole nangement initiative and union meeting type thing 23 24 and said the industry should be enccuraged to do it.
We 25 are taking several steps back avay frem that issue and O
my 9
. t
.m.
m.
m.
,come oa w-o m--
no oeoe*
c5 i.
1 in place with a level one, two and t,hree?
2 MR. DIR CXS :
I think there,have been 3 variations.
4 CO MI.SSIONER GILINSKY :
You nean insperters, 1
5 don't yo u?
.3.
VOLLMIE:
Yes, those are insperters.
4 s
7 There are specific qualifica tions f or those.
There is
~
8 no qualifiration standard, if you vill, for a quality 9 assurance sanager or any professionals in that sense 10 that deal with how he carries out his f unctions.
COMMISSIONER AHEARNE:
Could you say a few 11
~~
12 more words about th a t?
Ihere WW: some of materiel in 13 your paper and then in the OPE paper and let =e just i
~
14 address a couple of ~ sentences out of OPE's paper which 15 gets to the qualification issue.
16 Ihey say that with respect to qualification 17 certification of OA/0C personnel, the staff states, and i
1 18 that is you I quess, has been a' significant and 1
19 prevalent problem, that some utilities have valved the 20 education experience require =ents f or such personnel an d 21 the NRC has not sufficiently enforced these requirements.
22 COMMISSIONER AHEARNE:
I guess I wasn't aware 23 tha t we had re q uirem en ts.
There vere ANSI standards.
24 MR. VOLLMER:
ANSI standards which in many 25 cases the utility costits to following, but many of ROE:.SCN EP OM N G C C'.W *. NO.
44 1 qualified psrsonnel into the process.
We have had 2 pro blems in that area, as you knov.
I think lately ve 3 have been insisting more on a re vie w of the CA 4 or;iniration and we have seen some. changes there over 5 the util'ities.
6 COMMISSIONER GILINSKY:
Don't feel you have to 7 respond here.
8 COMMISSIONER EORERTS:
Eay I make a connent on 9 that.
I think Dick Vollner'said it absolutely 10 accurately.
It is not the program but it is the 11 exe cution, and that is the whole brute of the problem.
~
12 Nov vhen you say " program," if-:?6c are all inclusive and 13 include therefore execution,.then fine.
14 COMMISSIONER GILISSXY:
I would go beyond.
He 15 was distinguishing between what is on a piece of paper 16 and then how the organization as opposed' from that 17 ope rates.
It seems to me you have to qualify the 18 organization and it has to go beyond a piere of paper.
19 CHAIRMAN PALLADINO:
I think they have 20 elements of that in their proposal.
21 ER. DIRCKS:
We have the element of 22 qualification of personnel according to some sort of an 23 accepted standard.
That is scrething we have and ve can
~
24 review that initiative.
25 COMMISSIONER EDEERTS:
But isn't that already
- L E:S Os :E:0 C.G C O?.*: r. rey. C.
~
. ~. - - c c c. a an. n.
..a
46 o
1 these, like some of our other qualification 2 requirements, vill give an educational requirement, if 3 you vill, or e q ui va le n't experience or something like 4 t h a t',
and I think some people feel the vaiving of that 5 is a problem.
6 COMMISSIONER AHEARNE:
But to follov vhat I 7 thought the thrust of what Commissioner Gilinsky was 8 laying out, it wasn't clear to me from the caterial that 9 I could find in looking th r o'u; h our reg guides, standard 10 r eview plans, et retera, that we had what would say here 11 are the requirements for the OA personnel.
~
12 MR. VOLLMER:
I thin}f2fou tre right.
I am'not 13 aware of an'y.
i 14 CHAIRMAN PALLADINO:
John, do you vant to 15 proceed?
16 COMMISSIONER AHE ARNE:
I was just trying to 17 piggyback Vic's question.
18 CH AIRM AN PALLADINO:
I think he is finished 19 f or the coment.
COMMISSIONER AHEARNE:
Let ce ask a question 20 rhe organiration of OA vithin the NRC and let me 21 on 22 sta rt with a statement that Jack Zerbe had sentioned.
23 He used a quote of the top NRC O pe ra ting Ma nager in the 24 QA aiea.
Who is that person?
25 MR. DIRCK5:
Well, the office official that we b "
t 9Q,
- O kY, t'
47 1 look to have QA management responsibility is Dic.c 2 D eY oung.
3 CHAIRMAN RAL1ADINO:
Is who?
4 5R. D.IRCKS:
Dick DeYoung.
~
5 COMKISSIONER AHEARNE:
Jack, you were
~6 rentioned that at these meetings that the top QA ---
7 ER. ZERRE:
7 ell, it ought to be the top 8 personnel, whoever that might be.
9 COMMISSIONER AHE A R'N E :
Is that clear to you 10 that that is Dick Deroung?
_11 MR. ZERBE:
No, I gue..ss I could say it isn't 12 because the people in the fie162 den't report to him'and 12 t'he people'in ERE don't report to hin.
14 HR. DIRCKS:
It is as if we said who is our 15 top safeguards expert in th e ag ency, and my ansver vould 16 be John Davis who is Director of NMSS, or who is our top 17 official in charge of pressure vessel f racture l
15 integrity, and I would say Haro'id Denton.
COMMISSIONER AHEARNE:
Now as I understand it 19 1
20 the regional people are supposed to be working under the t
21 policy guidance of the Offic.e Director.
l MR. DIRCKS:
Right.
I 22 COMY.ISSIONER AHEARNE:
Can you sort of explain 23 l
24 to nd then how the interface is going to be made in the l
25 QA area?
For example, go through of the rationale of t
k g
hr t
48 1 why NRR's OA people veren't transferred over to IEE and 2 then also the interface of how the regional people are 3 going to be working under the policy guidance I guess of
~
4 Dick DeYoung in.QA.
~
5 ER. DIRCKS:
Let ne start off by saying I 6 vould look eventually to having the resources 7 consolidated in IEE because I think that is th'e 8 principle that we start off with.
9 COMMISSIONER AHEARNE:
Perhaps you vill get 10 why that eventuality isn't now.
~
11 MR. DIR CK S :
Y e,s, buA that is why I van.ted to
~
12 start of f ansvering your questE$b using the firs?
~
13 sentence.
The second sentence is going to fo11ov.
S 14 Having looked at what is going on in the agency in real 15 t er ms, I made a judgment, a proposal that f or the tine 16 being, and we are talking about two er three staff years 17 in NRR, that we keep those personnel in NRR vhile ve get 18 through this licensing process; the plants in the is pipeline.
COMMISSIONER AHEARNE:
Why?
20 21 MR. DIRCKS:
Secause in very practical ter:s I 22 a: looking to see what is happening in Diablo Canyon.
I 23 don't want to disrupt that process.
NRR is deeply in v o'1ve d in that and working ve ry closely on the 24 i
25 verification progran.
If we made an abrupt change, i
l ALCEESoN EEDCE7;NG COME t NY, iNC, e
e
~ ~ - o oan. ma ao
.n
... ~ na,_. % g.
99
~
~
1 sure, they could be vofking in ICE, but at the sec e time 2 I think ve could cause some disruption and I don't think 3 it is worth the pain.
4 COMEI.SSIONER AEEARNE:
You used Diablo Canyon 5 as the example.
Where are the people in OA in NER?
6 MR. DIRCKS:
They are working for Dick Voll er.
7 CHAIRMAN PALLADINO:
How many are there?
8 ER. DIRCKS:
I think two.
9 CH AIRM AN PALLADINO:
Is that all?
10 ER. DIRCKS:
Two or three.
ER. VOLLMER:
Two professionals.
11 COEMISSIONER AREARNEFOi?.y impression from-12 13 feading countless numbers of.Diablo Canyon transcripts 14 is that there are a heck of a lot of people fro: NER 15 involved and many of the: don't seem to be th o se two nor 16 Dick Yollmer.
So =y impression is that taking those two 17 and moving them to. ICE vouldn't have really ~ disrupted te Diablo Canyon.
19 ER. DIRCKS:
Well, it is a catter of judgment 20 I.think.
I tried to call it in the best var I could.
21 If at your level you think those two people are core 22 beneficial out of the 3,000 people in the agency to put 23 them over in ICE ve vill pu t them over there.
COMMISSIONER AHE A RNE:
I am really asking the 24 25 functional question because in the rationale that has n:E: SON EE:C:7 *.G COW W NC.
50 o
1 been present'ed over the last, what is it, eight qon'ths 2 since Joe wrote the memo in November there seemed to be 3 a constant thrust that' there wa s a real advanta e to 4 coalesce.
Yet,,when this final coalesring appeared it
~
5 see:ed to be that NER vas kept separate and I a: just
- 6 h av ing real diffiruity grasping your rationale.
7 CHAIREAN PAliADINO:
I also get the 8 impression, and I guess John alluded to it, th a t there 9 are far more people than just,these two that get 10 involved from NRR.
11 COMEISSIONER AHEARNE:
Exactly.
~
12 CHAIRMAN PALLADINO: Isst perhaps these'tvo' are 13 supposed to perform a coordinating function which I 14 gather they could do just as well in ICE as they cotid 15 do in NRR.
16 ER. DIRCKS:
I would say they possibly could 17 do it.
I at also saying there has to be some pretty is overriding reasons why they shculd be doing it and why 19 not let them assantially over the next year finish up 20 the work that they are doing in NRR and the n =ove some 21 people.
You are right, there are a lot of people in NER 22 vho are working on these problems.
'n'h e n w e have these 23 design verification problems cote in, sure there vill be i
24 a task leader and then they will have people in the 25 Eechanical Engineering Eranch take a 1cok at something k.
's b,
N a y.
n
51 1 and a lot of people in ths Design an,d the Seisnie Branch 2 do it.
It is a mat.ter of just assur.ing that we don't 3 disrupt the process.
4 Now f. rom the point of organizational theory, 5 yes, let's move then over, and I would be saying let's s nove them.
Eut on the other hand, if we can save 7 ourselves a little disruption, why not save ourselves 8 that disruption.
9 COMEISSIONER AREANNE.
But it seems to me Eill 10 tha t part of the whole theory that has to underlie this 11 paper you sent up is that the current process vasn't
~
12 vorking very well.
So you areC&&sru pting the precess.
13 You are essentially saying that there has to be some nev 14 initiatives I guess ~is the term that you have thrown in 15 there.
That has inheritly the concept that you are 16 disrupting, that you are changing the previous var of 17 doing things.
So I would guess that the disruption is 18 what is what you are looking fo'r.
I 19 ER. DIRCKS:
I don't think it is worth naking i
20 such of an issue of.
If the Commission thinks they l
l l
21 should go over there, then we can survive the going on.
COMMISSIONER AEEARNE:
Ia just trying to 22 I
t j
23 understand the argument why are 24 C05HISSIONER GILINSKY:
How many people voeld 25 he over under Dick Deroung?
l l
i
.:.t:E=sc, E:c :,c ::v::..n sc.
52 1
ER. DIRCKS: ' Fourteen.
2 YR. DeYOUNG:
Eleven.
3 YR. DIRCXS:
Eleven.
4 COMEISSIONER GIIINSK-Y:
That is bedore 'the 5th 5 or after the 5th?
6 MR. DeYOUNG:
After the shift 1 reserch 7 people.
8 COMEISSIONER GILINSKY:
And how any research 9 people vere th e re ?
10 ER. DeYOUNG:
Three.
11 I might add a point,t. h a t might, you kno.w,.
12 reflect that Ed Jordon vill hafiithe tas:. Of runn~1nd the 13 show with Terry Harpster without the NRR 1
4 14 responsibilities.
They have a full plat with these 15 initiatives that they have.
16 COMMISSIONER GILINSKY:
What are th e se people 17 going to do?
COMMISSIONER GILINSKi:
The 14 or the 11.
18 19 MR. DeYOUNG:
All of the initiatives.
They 20 a r e going to develop a progras, all cf these things that 21 you have before you.
COEMISSIONER GILINSKY:
What are they doing 22 23 right now?
24 ER. DeYOUNG:
That is what they are doing.
25 Rill said do it.
AL ERSON RE?C AM 5 CO.G e.Y. :NO.
oy e
i 1
CD MISSIONEE GILINSKY:
What vere they,doing 2 before you said to do it?
3 BE. DIECKS:
Terry.
4 EE. H.ARPSTER: We are doing it nov.
5 M E '. DIECKS:
Well, why don't you go through 6 sort of a functional description of the hranch and what 7 you are doing nov.
+H 8
ER. HARPSTER: What I a= doing right now is 9 borroving people from everywhere to get these things 10 done.
COEMISSIONER AHEAEFE:
Terry, could you use 11
~
-~
12 the cike.
ci 13 COMMISSIONEE GILIESKY:
Well, I am just trying 14 to get a sense for what cur CA organization was before 15 ve got into th e se improve:ents.
Hov big an organization 16 did we have and what vere people doing?
H ARP. T ER : What people were doing was~
S ME.
17 18 looking at the existing inspection program, what we do, 19 hov vell we do it and what ve can do to improve th a t.
20 As we develop the initiatives we start bringing more 21 people in from different places in the organization that 22 help us see hov ve can make the reco::endations ve have 23 nov.
COMMISSIONER GILINSKY:
Are they looking at 24 25 the entire inspection pro;ran or the ?A aspects of it, A LC E:S CN C E:0:7 *.G C O'.'; A'.v.
- C.
~...~ ~
a.
54 4
s 1 because it seems to me, you knov, that we go out and ve 2 inspect and find things wron; and that tells you 3
MR. DIRCKS:
Why don't you go through and 4 itenire.
You are writing the inspe.ction manual, you are 5 reviewing the inspection manual, you are appraising the 6 regions on how they are carryin; out, you a re acting as 7 the point of contact for regions.
Why don't you go a through that description.
9 COMMISSIONER GILINSKY.:
Well, that's it.
10 (Laughter.)
11 CO MISSIONER GILINSK.,:
We don't have to go Y
424-
~
12 through it again.
13 (Laughter.)
14 ER. DIRCKS:
I think that is what you are 15 looki ng for.
16 (Laughter.)
17 MR. HARPSTER:
We are involved in developing 18 all of the QA related inspection program concepts.
It 19 is not just th e Q A programmatic area but we interface 20 vith the Division of Programs also and almost all of our 21 inspection program has some aspects tha t are OA related.
COMMISSIONER GILINSKY:
Let me ask it this 22 23 vay.
At an early stage the two fellovs that work for 24 Dirk *Vollmer say res, the plans look okay and you can 25 get your license.
Nov from then on it sounds like some AL;E:!CNE: Car 4G OCv:e4* a;;.
1
-~~--
55 1 people have got to gather together and decide things 2 aren't going well out there in that' plant and maybe ve 3 have to do something.
There are no further approvals 4 that are r e q uir.e d from the N R C,.
Sc. you just go along 5 unless the NRC decides things are so bad that we call a 6 halt.
Is that about right?
7 5R. DIRCKS:
Maybe Ed can help.
8 COMMISSIONER GILINSKY:
So I mean at no point 9 do ve say yes, this thing is being implemented right.
10 ER. JORDAN:
Maybe I can help by saying the 11 problems that we have identified in the earlier 12 discussions vere the problems chtt we felt tha t -industry 13 didn't con' trol vell, that in.dustry didn't find at the 14 right time and that.the NEC didn't detect as quickly as 15 ve should have.
There are a lot of surcess stories 16 where the programs did work and where problens are 17 identified and are.being fixed.
18
'i h a t we are trying to change is change the 19 inspection progra= so that the things that the utility l
20 doesn' t find we are able to find more quirkly and then 21 further to affect the industry and the utility so that f
22 things don't get out of control.
The idea vould be that l
23 the quality assurance inspection program would find that i
l 24 the mtilities have an a ppropria te organiration and the l
25 organiration is working in findin; the problems before l
(
u:s:scuas: car.c ccu m.v.. c L
e e em..
56 1 the NRC gets involved.
That has got to be the gcal.
2 MR. DIRCKS:
Well, moreover, I think Jim 3 Keppler at one time came in to talk to the Cc :ission on 4 the' issue and he said we vere finding and t re a tin g 5 symptoms and we veren't trying to uncover the root cause 6 of the proble=, what was the sickness before ve can 7 prescribe the medicine.
I think that was the basic 8 problem of the whole effort.
We were two steps ahead 9 maybe et two ste ps behind finding a particular defect in 10 th e con struc tion program.
11 I think that we failed to do was to put 12 together sort o f a s y s t em a t ic -IZsA a t the d e f ect r ve-13 vere findihg and to trace it.back to some underlying 14 floor in the whole process.
That I vculd imagine is the 15 k ey answer to this whole probleo.
I guess if we have a 16 theory it is the fact that th e re was insufficient 17 man agement attention brought to it, and at what level I 18 think we have to identify.
19 COMMISSIONER GILINSKY.
Okay, we all agree 20 tha t there has got to be management attentien given to 21 it, but the manage =ent has also got to know what to do.
MR. DIRCKS:
Yes.
22 C05MISSIONER GILINSKY:
It seems to me tha t is 23 e
(
24 where ve have just got to say that ycu ha've te have a 25 satisf actory quality assurance systen operating and ve i
i l
l l
r.:E:s s :E:c: AG 003.9 t Nt NC.
l 57 1 got to say yes, that system is operating sa tisf ac.torily 2 for construction to. proceed beyond a[rertainpoint'.
If 3 ve insist on that we a'r e going to get managenent 4 attention.
5 MR. DeYOUNG:
Let me add a point.
We had n 6 OA Eranch in IEE until January of this year.
There was 7 no OA Eranrh in headquarters of IEE.
There was a
.8 Reactor Construction Division that treated everything, 9 but there is n o O A E ra n r h u n'til v e formed one.
After to your speech we began to think about it.
We had all those problems at some of the
~
11 12 plants and we recognired t h a t - 443 a d to have a special 13 group of pdople pulled aside.looking at GA alone.
That V
14 'is when Terry took th e b r a n c h ~ la st January.
15 CHAIRMAS PAiLADINO:
Dick, let me ask you a 16 question.
You know when we go to industry and say, boy, 17 you ought to have that QA operation reporting at the 18 highest level of anagement you' possibly can.
19 KE. DeYOUNG:
Yes.
20 CHAIRMAN PALLADINO:
And, yet, I am not sure 21 ve are following that advice if we are saying CA is down 22 here in a branch which is part of a division which is 23 part of a director's office.
If this the right level or 24 should ve put more emphasis?
COMMISSIONER GILINSKY:
Yes.
25
[
A:.:E;$CN RE?CRENG CCPMV, WC.
e 1
CHAIRMAN PALLADINO:
k'h a t led you to say the 2 branch level is the right level?
MR. DeY3dNG:.
'J el l, the branch isvel, ve take 3
4 a look at the-size of the group.
The group is only 10 5 p eo ple. * -It is not a division.
'J e like to think a 6 division is like oh 60 or 70 or 80 people.
Ihat is a 7 division.
A branch we think is something on the order 8 of 10 to 20 to 25 people.
9 CHAIREAN PALLADI!:0:
Suppose the industry felt to that way and they said, well, this QA isn't as major.
11 MR D.eY OU N G:
Rut the,y have quite a number of 12 people.
They have learned f ro5 5%;e rience tl at th e y' 13 need hundreds of people in their QA orgagnizz ion.
They 5
14 have a large organization.
15 CHAIRMAN PALLADINO:
But I rememb er this being 16 a major issue ten years ago and even longer than that a 17 little bit and yet,those organirations were small and we is said, boy, he is reporting to this g uy where he ought to 19 be reporting up here.
20 ER. DeYOUNG:
I don't think ve have the same 21 problem that they have.
They have a problem of seeing 22 the plant constructed on time and going on line on 23 time.
'J e don't have that problem of conflirting 24 responsibilties.
I talk to Ed Jorda n, f or exa mple, 25 every da y.
I neve r miss him.
He never misses me.
At.CE;ECN AESC:7 *. G C C Y A*.Y... C.
AfoYCmTAav: 3-
.. P' 3 70' 0 0. 000:1.000159 095.*
59 e.
4 e
1 Sometimes early about 2 or 3 o' clock in the morni-ng ve 2 have discussions on some things.
'n'e o f t e n talk.
It is j
3 not that we are separa ted.
4 COMMISSIONER AHZlRNE:
Eut, Dick, Ed isn't the 5 person in charge of QA.
6 MR. DeYOUNG:
He only has the three groups 7 under him and he talks constantly.
He is deeply 8 involved with them.
He is not separated from them with 9 other responsibilities.
IeEry only has ten people.
10 Special problems come up in OA.
They come from Ed 11 Jordan mostly.
He has an. Engineering Branch and he uses 12 them to supplement Terry Harpsfii's branch.
~
~ -
13 COMMISSIONER ARIAENE:
I am not sure I 14 disagree with your argument, but I would just point out 15 th a t the linkage that you talk to Ed every day and.Ed 16 talks to Terry every day sounds an awful lot lik e what 17 ve heard from some.of the licensees.
I can remember a 18 particular utility sitting acro'ss the table from us here 19 in this room and we asked well who is in charge of this 20 and t.he answer was well it was so and so, and we asked 21 vell why isn't that at a higher level and the answer was 22 vell I talk to "X"
every day and "X"
talks to "Y"
every 23 d a y and "Y"
talks to so and so every day.
So the 24 linkage is really there.
25 COMMISSIONER EC3ERTS:
"J e l l, I think you make 1
t.: :sc, :s:c:,o ::v:e.-
J
~
1 1 a good point though.
I don 't think there are the same i
2 conflicts within NBC that there migh t be in a corporate 3 entity.
4'
~
CO5KISSIONER GILINSKY:
T.here are conflicting 5 pressure's here, too.
I don't think we ought to kid 6 anybody.
7 E. DeYOUNG:
Not of the same magnitude.
8 COMMISSIONEE ROBERTS:
I didn't hear the end 9 of what you said.
There are conflicting pressures what?
10 COEEISSIONEE GILINSKY:
There are conflicting 11 pressures heye, too.
~
12 EE. DeYOUNG:
There 424, but not cf the sane 13 =a;nitude.'
i 14 COMMISSIONER R3EEEIS:
I think not of the same 15 =a;nitude at all.
l l
16 EE. DIRCK5:
There are different concepts.
CHAIR 5AN.PALLADISO:
'J e l l, I am net so sure.
17 18 T ha t is why it was last November ve felt things were out 19 o f hand so =uch in quality assuranre that we felt we i
i 20 needed a real focus on it and called for it.
So there 21 was a balance of pressures that was getting distorted 22 enough so that we didn't think enough of the pressure I
23 vas going on OA.
So I am not sure.
I am not saying it 1.
24 D.as to be a Division, but it does stike me that it seems 25 to be buried down in the cr;anization the way OA used to CE:!CN O E:C'T"eG COVNWY..NO, o
61 e
a a
1 be in ost of the utility line-ups.
That is just an 2 observation.
3 MR. DeYOUNG:
It is a consideration.
You 4 knov, when ve talk about the enforcement group, ther 5 report tA me and all these little groups are very 6 important.
7 C0!MISSIONI3 GIIISSKY:
Isn't that the most S important thing that our inspectors have to do is to 9 sake sure that that quality' assurance systen in each 10 facility at each site is operating properly ?
11 HE. DeYOUNG.
In the broad sense yes.
If that
-~
12 is working right we have got a -es # e plant and a well 13 constructed plant.
In a broad sense it is.
14 ER. DIECK S :
We have pecple on site who are 15 directly inspecting.the constructien of the facility.
16 We have the divisions within the regional offices with 17 their construction. specialists relating back to the 18 residents.
The OA office in he'adquarters is not the is only office that deals with the construction program.
20 T h e QA people here are developing appraisals and they 21 are developing manuals.
They are not actually out there 22 on site reviewing construction.
When you say, or I 23 think somebody pointed out that we have insisted on 24 utilities ha ving a separate office of OA.
That is to 25 counterbalance the construction bosses, and you vouldn't l
AL EssoN PE: :T NG : v:v.t 'NC
62 1 vant the OA people working for the ccastruction.
2 superintendent.
That is why we have 'that separation.
3 We have a lot of high priority ef f orts in the 4 agency that always come up.
It is OA today and
~
5 licensing last year and we have steam generators next 6 week.
We just can't have the: all reporting directly to 7 vhatever cana;enent is around.
8 CHAIRMAN PALLADINO:
Do you want to proceed 9 with more questions?
10 COMMISSIONER AHIARNE:
I am sorry I had to 11 step out and perhaps you,have t..nswered the question,.
In 12 your pa per y ou list NRC staff iEbources are abouE 25' 13 staff-years per year new effort associated with these h4 14 programs.
One of the items you have is the integrated 15 design inspection idea, which I gather vould involve 16 NRR, the region and ICE.
17 On the one hand you have a relatively s=all 18 b ra nch and on the other hand you have a large 19 description of a lot of efforts.
I guess I am concerned 20 a re you really going to make successes out of all of 21 these initiatives and have you seriously looked at how l
22 big an effort it is that you are initiating?
It is i
23 almost as though you have got a policy paper and some
(
I 24 policies laid out, but it is not obvious to me that you
{
25 have allocated the rescurces to carry through en all cf f
ACE:50N :E C E* ".G CO V: WY..NC,
(
63 4
1 those.
Another way of saying it is perhaps you have 2 bitten off more than you can chev and you ought to have 3 focused on a fewer set of ideas.
4 MR. DIECKS:
Scie of these are phasing out.
\\
5 The NT01 effort in NES has a date when they vill be out
'+
's of existenre anf others are roting in.
But I think your 7 point.is valid, do ve have the right =ix of rescurces a here.
9 COMMISSIONER AHEARNE:
You have got a large 10 number of reports that vill b'e coming in.
11 33..
DIRCKS:
Ye,s.
12 COMMISSIONER AREARNEf*EThe staff ha s h Ed a 13 problem in the past, and not-necessarily the IEE staff, 14 but the sraff in general of asking for a lot more 15 raterial than it can usefully absorb and respond to, an d 16 I am vondering whether you aren't following th a t sam e 17 pattern.
18 MR. D BCKS:
It could be.
We have a lot of 19 initiatives and a lot of activities.
'n' h e n ve vent over 20 this I tried to get from the staff whether we have the 21 right amount of resourres ;oing into it.
I have been 22 told we do and I have been relying on that.
As it 23 develops and as ve get reports in, de ve have the right 24 number of people to handle it.
25 COM!ISSIONER AHEARSE:
For example, ycu have
- C.
ALCE:50N :E F O : ?.G 2 0 '.*: a.-
6u s
~
1 commitments out of NRR' Does ICE have commitments out 2 of NRR and the regions to commit the people that you are 3 going to need?
4 MR. HARPSIER:
Yes.
5 COMMISSIONER AHEARNE:
A commitment in the 6 sense of allocated spaces or ---
7 MR. HARPSTER:
We have some of those people 8 vorking with us now.
I have people from different 9 division s wi thin ICE, for instance, vorking on the 10 design initiative.
11 COMMISSIONER AREARNE:
I am sure you can get
~..
C h-d the regional reople 12 the ICE people.
It is the NRR 13 that I am questioning.
It is just an unease tha' I have 14 and I guess I will probably put it in writing, b5 - that 15 is a concern.
16 I guess the last set of questions I had related to the designated representative proposal.
17 18 Bill, I guess what confused me'vas you vere asking for 19 approval of something and it wasn't clear to me that the 20 idea had been fleshed out far enough to be asking for 21 approval of anything.
I ga ve a se t of questions such as 22 vhat are the criteria for selection, what would you pay 23 them, who would supervise them, what was the overla p of 24 the' certification concept and what has been the FAA 1
25 experience.
Is that all material that you have or is l
l l
l I
ALCE:SCN D EOCEIAG Coh80 &NY 'AC.
65 r
1 that part of what you are developing 7 2
ER. DI R CK,S :
We have some'of it, but I do vant 3 to stress that I have got many questions on the whole 4 thing myself.
What we vanted.to do.vas to get it before 5 the ComEission pretty soon so you would know what we are
~
s doing.
As soon as ve start talking with FAA and word 7 leaks cut what we might be thinking, ve didn't vant this 8 to come in and surprise the Commission f rom some other 9 source.
10 CH AIRM AN P ALL ADINO:
Then you are really 11 asking for our endorsement of your proceeding to develop 12 a proposal.
-=1,.
~
13
- 13. DIRCKS:
Shou}d we pursue the concept.
5 14 The concept may be so nev and novel and so filled with 15 questions that you may tell us to forget it.
16 COEMISSIONER AHEARNE:
I guess for =yself I 17 v ouldn ' t say give approval to develop the proposal.
I is vould say to explore the proposal.
19 CHAIRMAN PALLADINO:
To what?
20 COMMISSIONER AHEARNE:
To explore the proposal 21 because there are a number of questions.
22 ER. DIRCKS:
I agree.
I think there are lots 23 of questions and we have been throwing those questions 24 around ourselves.
We just wanted to at least surface 25 the ides and let you knov that we are thinking of it.
4t:E:scN nE=c:ms :v.ov v. :sc.
~
L4T3 A
6 0
1 We could tell you what the results are thus far.
I 2 quess there have been conversa tions with FA A and their 3 initial contarts I g uess.
Id,
I.
uess, he has pursued 4 these convarsations with the Federal Aviation 5 Administ* ration.
.6 COMMISSIONER AHEARNE:
What I do need is more 7 information.
8 CHAIRMAN PALLADINO:
I hava a bunch of s questions also on this designated representative, but I 10 vonder how formal we need to get in our concurrence to 11 proceed further on this.
I think more research is 12 needed and I think you agree oscthat.
There are e 13 number of questions that hace to be ansvered.
If things 14 look lik e th ey can work for us, then a proposal cocid be
)
15 developed.
16 COMMISSIONER AHEARNE:
I think you really have 17 to talk with some of the industry, too.
18 E. DItCKS:
Oh, y e s..
19 CHAIRMAN PALLADINO:
I think industry input on 20 this vould be particularly important.
They are going to 21 get involved and they are going to ask the same kind of 22 questions ve are asking except they vill ask them with 23 more intensity.
COMMISSIONER AHEARNE:
There'is another 24 25 point.
I am not sure where you voeld go for the cs:s:s t::c:ss coaw s:
......m.
67 1 additional vi?v, but there probably is a question of do 2 va and the FAA share the same kind of certifica tion 3 responsibility.
I think sonevhere in your paper you 4 said that the use of this, or maybe.it was in Jack's 5 paper, but the use of it would help us increase the 6 confidence when ve certify.
I am not clear at the 7 moment to that e'xtent we ran tra nsf e r our resposibility 8 for certification.
You know the great debates we have 9 had about to what extent can ve rely on FEM A and other 10 f ederal a;encie s.
11 COEMISSIONER GILINSKY:
Well, if you are
-~
12 talking about a change in the 244 If you change the 13 lav you cah do anything you,vant.
5 14 CHAIRMAS PALLADINO:
The lav v0 1d have to be 15 changed to be more conparable to the FAA.
16 COMMISSIONER ROREETS:
What is the neaning c 17 slide 17, this is under "De signa te d R e p rese n ta tiv es -
18 Implementation. "
" Preliminary' study of FAA system -
19 3/82."
What does that consist of?
Is that infornal?
20 ER. DIRCKS:
It was informal contacts with 21 FAA, and tha t is about all.
COEMISSIONER RORERTS:
I was just asking.
22 ER. DIRCKS:
I don 't think ve have anything 23 24 formal to present to you, but I think the questicas that 25 have been raised by you are the very questions we vould t.t:E:SCN :E:C:
.3 00r.':..< ' 0.
68 1 vant to see'some ansvers to before ve move very tuch 2 further.
Eut we didn't vant to move very much further 3 until we lat you know what we are doing.
4 0MMISSIONER AHEA?NE-Sut it sesas to me that 5 you have already b e g un to talk about proposed rulenaking.
6 ER. DIECKS:
Only the schedule.
It is only 7 some =ilestones there, and if we didn't have those ve e would have anything 9
COEMISSIONEE AHEARNE:
Vic had just said that 10 legislation would be needed.
You have down further 11 " Prepare rule and legisla tion. "
By identifying the eld
~
12 and OGC representative for pr:f9hed rule m a k in g hi7e "you 13 reached a ' tentative conclusion that you don't need i
14 legislation?
15 ER. DIRCKS:
I think it is so up in the air 16 that we could go either way, if ve ;o at all.
It is 17 really pretty undefined right nov.
18 MR. CUNNINGHAM:
I think our tentative 19 conclusion, and in fact it is probably acre than 20 tentative, is that we would need legislation.
21 COMMISSIONER AHEARNE:
Let me say on this you 22 are six mon ths away fron starting a pilot progran.
23 ER. CUNNINGHAM:
L' e ll, I have som e question 24 about that slide.
25 (Laughter.)
- C.
AL E:50 4 :E:O C '.G CO?.* W 4Y
69 1
ER. CUNNINGHAM:
But I d o n ', t think if ycu need 2 legislation for the. program that the, pilot program can 3 go all the way without that legislation.
4 MR. DeYOUNG:
I like the thought of a progress 5 report on each of th ese about every th ree months.
We 6 vould not just go ahead and do somethin; and then come 7 with a completed package.
I think a report to you on 8 each of the initiatives would be useful.
9 There is another strong point when you look at 10 all of the initiatives there, there is a critical one 11 that we have no. control over, and that is INFO.
If they
~
12 d o not do what we expect them t344o, th e n v e h a v e-t o-13 ste p back and do a lot oore..
~
s 14 COMMI55IONEE AHEARNE:
Is the converse true 15 t h a t if they do what has been described tha t they a re 16 going to be doing that you vill then do a lot less?
17 MR. DeYOUNG:
I don't think so, not at this 18 time, not until we are sure wha't they are doing as ve 19 had in the operating plants.
COMMISSIONER AREARNE:
So are you saying that 20 21 from your view this program that you h' ave laid out is 22 what is required to mesh.ith a fully successful INPO 23 program ?
24 MR. DeYOUNG:
Yes.
COMYISSIONEE GILINSKY:
Could you pursue that 25 AL;E:5CN :E:C: M COv;r v. ;'C.
70 t
(
i 1 a little more?
It troubles me a little.
With all due 2 respect to INPO, it,seems to me ve hive got certain 3 responsibilities and va have got to carry them out.
Nov 4 hov is what you plan to do affected.by what INPO does?
I 5
ER. DeYOUNG.
"e have only so cany resources l
'6 that have been nade available.
We have experience with i
7 the INPO group vith their review of the F A: type of l
l 8 program.
Not too long ago ve had sone 20-some people in i
9 our PAT prograc.
We need thec for CAT and ve needed 10 them for the other prograns.
We took a look at what we i
11 knew about the.INPO program and we vere encouraged.
We
~
12 v er e impressed with what they is e doing.
13 We thought we could spend less resources de. q 14 'the Pr.1 type of reviews and we came to the Co:missio.
15 vith it and told the Co :issian what INPO had been doing 16 and what our review of that had indicated and ve stepped 17 b s k.
We told you ce conld reduce the resources by 18 about 50 percent and use those' resources some place else.
19 Knoving what the organiration can do, ve ate 20 almost convinced that if they do the progra: that we 21 think they might do, we 'think if we conitor those 22 p r o g r a m s, :onitor the programs they have for the 23 operating reactors, ve don't have to do as much verk.
24 We a're resting on the experience ve have with their 25 performanca in the operating reactor progra:.
4;; E: $ s c E: c :
',G c i.* :1.v NO.
71
~
1 CHAIRMAN PALLADINO:
I think there is an 2 important point that is related to this.
I think in any 3 society policing is odly a reasonable possibility if 4 most of the people obey the law.
Here what we are 5'talkingIbout is an organization to help self-police the
'E ind ustry so that when we go in ve find fever things 7 vrong, not that they are not tryig to obey the'lav, but 8 the law is so complicated that some organization 9 discipline is needed to get compliance.
10 Before ve leave the designated representative,
~
11 let me ask the Commission if th,.ey would like to express l
12 a t this point a desire to ask tni-staf f to explore this 13 datter further and then come back with better research 14 and a better considered proposal on this so ve don't
[
15 have to take a formal vote unless you want to.
i 16 COMMISSIONER GILINSKY:
Well, ve asked then to 17 do that on February 10th?
18 CHAIRMAN PALLADINO:
'Did ve?
COEEISSIONER GILINSKY:
Yes.
19 20 CHAIRMAN PALLADINO:
What, in a staff 21 requirement?
22 COM5ISSIONER GILINSKY:
It says the Commission 23 requested that the staff examine the cuality control 24 program used by FAA, which I take it includes this.
25 CHAIRMAR PALLADINO:
They asked us.
9 9
,e
i 1
COM5ISSIONER'AHEARNE:
Well, no, we are still 2 asking them.
We' asked them on February 10th.
3 (Laughter.)
{
\\
CH$IRMAN P ALL A DItiO:
Eut nov ve are asking
~
4 5 them to explore in more detail a proposal.
6 COMMISSIONER'GILINSKY:
We forgot about it so 7 nov ve are asking them again.
8 (Laughter.)
1 l
9 CHAIRMAN PALLADINd:
Six months have gone by.
10 COMMISSIONER AHEARNE:
They haven't quite done 11 vhat we asked them to do.,
~
m
~
12 COMMISSIONER GILINSK [A The thing I wasted' to 13,ask is did'this seem like a promising notion?
l 14 ER. DIRCKS:
I thought we vere doing what you 15 asked us to do.
16 CHAIEEAN PALLADINO:
No, but you asked nov for 17 approval to proceed, and we are saying okay, we are 18 giving you approval to proceed / but come back vith a 19 more considered package.
20 COMMISSICNER GILINSKY:
Does this seem like a 21 promising idea on the basis of a quick look ?
22 ER. DeYOUNG:
I am convinced it is.
s 23 MR. DIRCKS:
Well, there are pros and cons 4
24 lik e ' eve rything else.
25 (Lau hter.)
Acs:s cr, :E:c:nss Ocv:w. NC.
73 1
ER. DIRCKS:
'I t s e e.t. s to be working in -th e 2 aircraft industry,.n e t only from the~ point of view of 3 the FAA, which is very high on this concept, but it 4 seens to be working not to th e. displeasure of the 5 industry itself.
It seems to be functioning in an 6 t;propriate vay.
It is an extension of resources and, 7 God knows, we Deed to extend our resources to the e x ten t 8 ve can.
9 But there are other questions.
Are ve dealing 10 here with a completely different industry?
There you have a facto.ry plant environnent and you can do this 11
~
d is ciplin eizs-it in a closed 12 sor t of thing is a 13 environment, so to speak.
That is different from what 14 ve are facing.
What vould we get out of it more th an 15 w h a t w e have now?
We have conpany QA officials by 16 anointing them or by giving them an arn band or 17 so:ething like th a t.
What do ve gain out of it?
I 18 think that is what we vant to e'xplore among ourselves.
19 What sort of complications does this add to the already 20 complicated process we have onhand?
I don' t think we 21 have come up vith those ansvers.
22 If you look at it first blush, I think Dick 23 vould say it has some potential.
If you look at the o
24 othet side, it has potential for problems.
That is vha t 25 ve vant to pursue.
It is controversial.
AL E:SCN RE:C TWG COVF ANY, INO.
14 o
1 You asked earlier has industry reacted,to 2 a,n y thin g we have talked about in this teeting.
If they 3 have reacted in any way, they have reacted adversely to 4 this proposal.
5
( L'a u g h t e r. ')
6 C$ AIRM AN P ALLADINO:
Do you each vant to go 7 back and fill out your own voting sheet on this question?
8 COMMISSIONEE AEEARNE:
Yes.
9 COMMISSIONER ROBERTS:
(Nodding affirnatively.)
to COMMISSIONER GILINSKY:
(Nodding 11 affirmatively.)-
~-
COMMISSIONER AHEAENEF i{ Nodding affirnrtively.)
12 13 COMMISSIONER AEEAINE:
Could I ask one other 14 guestion on the FAA matter.
I noticed the FAA has just 15 published'in the Federal Register what they describe as 16 a sweeping change in the approach that they are taking 17 in regulation going to what they call regulation by.
18 objective as opposed to d e tailed r eg ula tion.
Do you 19 knov vhether that is intended to have any modification 20 of the FAA program?
21 MR. DIRCKS:
I haven't seen it.
COMMISSIONER GILINSKY:
A version of 22 23 regulatory reform.
24 (Laughter.)
COMMISSIONER GILINSKY:
Actually, I don't know 25 cs:s s =.E=c: sa c:v:v.-
--_,_m
75
..t
~
~
1 whether you are closing at this point.
2 CHAIRMAN PALLADINO:
N o, I wanted to give Tom 3 and Jim a chance.
Ihat was why I was trying to c1cse 4 this issuo.
5 COMMISSIONER GILINSKY.
I suppose they have
~ 6 five minutes each.
7 (Laughter.)
8 COMMISSIONER ROBERTS:
I will give you part of 9 =ine if you want it.
10 (Laughter.)
CHAIRMAN PALLADINO:
He has already had part 11
-CM-
~~
~
12 of yours.
13 (Laughter.)
14 CHAIRMAN PALLADINO:
Go ahead.
15 C0!sISSIONER ROBERTS:
Well, sost of ny 16 castions have been asked by others.
I an a little 17 initially skeptical of a designated representative.
I 18 d o n o t have a closed mind and I think it is appropriate is for the staff to provide us some more information, but I 20 don't think ve ought to be expending a lot of money and 21 resources at this point.
I think we can ;st enouph 22 inf ormation to see whether ve vant to pursue it further.
CHAIRMAN PALLADINO:
Ji:.
23 COMMISSIONER ASSELSTINE:
I had a couple.
24 25 Nov that INPO is be; inning to start its own
~
ace:scs :E:c=
,c ccvem.
.c.
yg -
m I
O 1 self-evaluation p r o g r a s., what thought have you given to 2 whether you want to continue our self-evaluations or 3 whether you want to tailor them more to the ore 4 structured appr.oach that INFO is following or whethe r 5 you want'to continue the: just the way they are?
s ER. VOLLMER:
I think that we would vant to 7 tailor up on those or drop them.
If we felt that the 8 IN?O vork in combina tion with the integrated design 9 r ev iew initiative proposed here vere successful 10 initiatives, I think we would use those to take the vould be vell defined, structured and we 11 place and they -
12 would be getting out of the a d rh?de-is hn es s of th e-13 c'ur ren t inde penden t design review process.
Sc I would I
14 see those as taking over from that.
15 ER. DeYOUNG:
The INFO review that they did 16 t h e self-evaluation, they knew they could not establish 17 the standards that they have while they did every 18 plant.
They said we can't do any of the plants for the 19 nex t year.
So ve have to do them.
They did not do them 20 yet.
So ve came in with an unstructured program that 21 depended on a lot of judgment that Dick and his people 22 used.
But once it is in place and once ve see that it 23 has been effective, I think we vould begin to phase out 24 curs.
COMMISSIONE3 ASSELSTINE:
On the independent 25 AL E:.s:N:E 00.7:*.G CC VE M *. NC,
l J. J.
e 1 design reviews, I was a little but unclear as to hov 3ou 2 about making a decision and -the extent to which yo'u try 3 and influence the util'ity's decision on whether they ;o _
4 for-a more expanded third-party audit like th e San 5 Onofre review or a much more limited audit say like the s La Salle reviev was.
To what extent do you try and 7 encourage a particular plant to go one var or the other, 8 and what kind of factors do you take into account in 9 that management meeting you 'have in deciding which way to you vant to try and push them?
11 ER. VJLLMER:
Jur encouragement so far has abs, a d e fici en c y 1n th e 12 been trying to meet what we sa or an independent look at the design is design review 14 process itself.
I don't recall that ve enccuraged 15 anybody to take a vary broad look.
I think in many 16 cases the companies did have broad looks at CA initiated 17 by other parties as a part of their overall QA program 18 within the utility.
So I think' those that came in with 19 broad programs case in because they felt they wanted 20 that assurance.
Palo Verde did and San Onofre did, 21 excluding Diablo Canyon as a special ca se.
The others 22 are fairly narrow in extent and looking, basically a t the 23 procedural and technical design process.
C O F. MIS SIO N ER GIIINSKY:
Didn't they basically 24 25 volunteer those programs and we ag re e that that was AL E:$0NE C :'*. 3 C O.1F D.v.
- C.
78 1 satisfactory?
2 ER. VOLLMER:
Yes, they di3.
We could hardly 3 turn them dova.
They were very attractive looking 4 programs.
But.v e didn't try to javbone anybody else 5 into programs of that extent.
'6 COM ISSIONER ASSELSTINE:
I guess wha t I am 7 vondering is are there factors tha t you looked at in, 8 for example, trying to decide whether you vanted to 9 javbone somebody into a more expanded procram if they 10 cam e in with a very narrowly defined one?
11 ER. VOLLEER:
Well, s..peakin; for NER, I think
~
~
12 it was the joint collec ti ve vi656c of ourselves &md"the 13 ICE organiration and the regions that the overall and I hope tha t tha t 14 program needed another scrutiny, 15 vould have been part of the ove rall process as ve vent 16 through the construction of the plant, then I guess one 17 vould say you vould try th a t.
18 The second possibilit'y is if the independent 19 design review uncovered some generic flavs in their 20 design proress, we vould va n t them t o l o o'r, f urther and 21 this could expand into a more progrannatic OA look.
22 COMMISSIONER ASSELSTINE:
On the procedural 23 changes, particularly the revisions to the inspection 24 effort, could you briefly describe for me nov how the 25 distribution is made of the inspection effort nov?
h b. *
't e's t
4
79 c-1 Depending upon the stage of construction, for ext =ple, 2 is most of the inspection effort now allocated to plants 3 that are fairly well a'l o n g and in the latte r stag'es of 4 construction and a relatively limited effort in the 5 early s th~g e s~?
Then could you tell me hov you are going
~
- 6 to distribute the' increased inspection effort that has 7 already been projected for '83 and '847 8
ER. DIRCKS:
Ed.
9
- 52. JORDAN:
As fa'r as the distribution is a 10 function of completion, it is more distributed in terms 11 of the rate of completion than it is the degree of
~
12 completion and it is by the stE44-In the early stages 13 there is n6 electrical work.at all.
So the people who 14 are there are looking at the concrete placement and the 15 steel placement, the erection of steel.
So it is 16 dif feren t skill levels and it is proportional to the 17 rate of construction, and the quality assurance aspect 18 o f it vould be depending on v h rt contractor is there.
19 Each contractor goes into the construction site in a 20 7iven area and then is particular quality assurance 21 program and personnel are examined and then on to the 22 next one.
So it is a very structured progran in that 23 24 kind *of a respect.
For instance, our manpover figures 25 are based on th e percent of c::;1etion and rate.
s u:E:s:. :s::
- ::v:v.<
80 i
1 COEEISSIONES'ASSE1STINE:
How about the 2 increases, are they going to be fairly well distributed, 3 the increased effort?
4 MR. J.ORDAN:
The increased effort I would say 5 right now is simply distributed informally.
I don't 6 think ve could say that we have shifted it, but the 7 inspection progra: itself is being revised as one of the a slide indicates so that we are emphasizing the actual s vork rather than the paper Eecord of the verk and then to looking at the quality assurance.
11 COMMISSIONER AS,SE1STINE:
I wanted to ask ycu,
'ndicates sone te55$tiv e j udgm en t thi+ 'that i
~
12 too, if that 13 was part of the problem in our inability to identify
~
14 some of the QA breakdowns in the past, that we are 15, focusing too much on paperwork review and not on an 16 obs er va tion of actual work, or that we veren't putting 17 enough emphasis on. design or design changes?
~
18 MR. JORDAN:
Ce rtainly we feel that we veren't is putting enough verk on design and design changes and 20 that our program did not emphasize that area 21 sufficiently.
22 In terms of the a ctual wor k, part of it is 23 ef f ec tivene s s.
If you find a problen at a site during 24 an inspection and you find it in terms of the records 25 aren't well maintained or somebody didn't sign a box, AL E: EON RE:0:
3 0 v:v.Y. 3 0.
81 o no.
1 you don't get the utility's attention v ery well es 2 compared to vhen yon look at a component and you find a
~
3 physical defert, a concrete placement isn't being 4 controlled adequately or the slump isn't correct, and 5 then show that the procedure didn't have sufficient 6 controls on it.
7 So you have to have a mix.
Simply looking at 8 the papers is insiequate and simply looking at the work 9 in progress is not very efficient.
You can 't cover an 10 awful lot that var.
So it is a good ix that we are 11 looking for._
12 COMMISSIONEE ASSELSTfi'.
On the allocEtion of
?
13 resources,'particularly Table 1 in the SECY paper, for 14 =anagement programs it appears that that is where the 15 vast bulk of the industry effort is, 270 out of the 250 16 can-years are in management programming.
Is that the 17 INFO effort or is that these management vorkshops,.or' 18 w h a t is that that the industry'is going to be doing?
19 MR. JORDAN:
That is based on the manage =ent 20 verkshops.
That is the meetings with staff.
21 MR. DeYOUNG:
By staff they mean the people on 22 sit e, the 3,000 people.
If they teet for a half a day 23 that is a lot of man-years.
COMEISSIONER ASSELSTINE:
I had a rouple of 24 25 questions th en on the long-ter reviev.
Is the v.: s scu :::::-,a :va,y. s:.
g2
- e % +
1 timetable that you have for the long-term review -
2 realistic, that is you can vrap it u; by the end of '83?
3 5R. HARPSTER: That is really based on the 4 proposed authorizing legislation.
We have set a 5 schedule' backing up from that.
6 COMMISSIONER ASSElSTINE:
One thing that you 7 mentioned, Eill, about the informa tion on cost, would it 8 be possible as part of a long-term review t o at least 9 collect information on what the costs have been that to have been incurred at some of the problem sites?
I knov 11 that gets a little bit far afield frc: what we are
~~
12 supposed to be vorrying a bout, rs6e I also s uspec t-that 13 y'o u are probably right that.when the cost figures come i
14 out for some of the sites a t which the QA breakdowns 15 have occurred that that more than anything else is going 16 to be a strong incentive to encourage a strong 17 management commitment.
18 ER. DIRCK5:
I think in these manaement 19 seminars we vould hope that some of this co uld be 20 brought out.
When you figure costs, some of these 21 plants are going to ask for reverification programs.
22 The costs are really tremendous.
When you shut down a 23 project'for several weeks or a ccuple of menths, again 24 the costs ge t astronomical.
If ve can get some feel it 25 vill be gross estimates and I think ve vill try to push 4.:E=scs :E=c:.s ::v:e, s:.
~
-........... v
83 ir.
1 for something like that.
2 COMMISSIONER ASSELSTINE:
That is all I had, 3 Joe.
4 CEAIRMAN PALLADINO:
I wonder if I might make 5 a couple of remarks.
This is a subject that is of 6 c on tin uin g interest to the Commission.
I think the 7 initiatives do represent a significant step forward.
I a still have a number of questions in certain areas.
I am 9 particularly interested in the relationship to the 10 regional inspection program and hov vill ICE 11 con solida tion interaction, with..th e regions.
I think n
12 other Commissioners have concerns as well.
hith regard to th e de signa ted representative,
~
13 14 I think va vill have to seek responses on notation vote 15 from each of the Co=missioners.
I vould suggest that we 16 revisit this subject in the not too distant future to 17 see how we are making out and what sort of reactions you 18 do get from industry as the program proceeds.
19 Any other comments?
COMMISSIONER GILINSKI:
Yes.
I veuld very 20 21 zuch like to have this idea persued of a : ore formal o
certification of quality assurance programs as a 22 23 prerequisite for goin; beycnd certain hold points.
In 24 other vords, you have to be up to a certain level and 25 get beyond a certain point Of c:nstructica and up to a 4: 1: ! :. : g:::
.3 : ?.*: * *.*
.0
64
- s' E.
a
~
1 higher level and be able to deal with a larger vrriety 2 of equipment to go beyond a further level and so on.
'3
!E. DIRCKS:
I think we have to look at it 4 because I am really unsure of what ve are doing right 5 nov.
I think what we have to do is take stock of what 6 ve actually do right nov.
I think what we should do is 7 p r o vid e, first of all, a pretty concise summary to the 8 Co==ission of what we do right nov.
9 COMMISSIONER GILINSKY:
'/ e ll, I would 10 certainly appreciate that, too.
CHAIBKAN PALLADINO: ~3ct I think important to 11 12 such an ef f ort would be how we is that quality'~,
13 assurance tea: vorking beca tte it could look good on j
14 paper and it i;ht have numbers that you think are 15 appropriate.
You have got to have people whose 16 credentials seem to fit the requirements of the 17 organiration.
18 ER. DIRCKS:
Let's see if we can put something 19 together in terms of types of structures we have now and 20 What,ve know about qualifications of personnel and 21 perhaps relate it to our experience with the QA program.
COErISSIONER GILINSKY I an talking about 22 23 revieving an organiration in being as opposed to some of 24 the reviews you have conducted which are reviews of 25 plants.
\\
i AL:ERSON AUC AT:N3 COY 8 ANY WO 85
. I ', "
w 1
3R. DIRCK5:
'I think it would be interesting 2 to take a snapshot of this thing and,then we can s'ee 3 where we go from there.
4 CHAIRIAN PALLADISO: - Anything further ve 5 should take up st.this time?
6 (No response.)
7 CHAIEMAN PALLADINO:
. ell, thank you *.'ery such.
6 We vill stand adjourned.
9-(Whereupon, at 5:d0 p.m.,
the meeting to adjeurned.)
11 g
.r.x,
~.
13 m
14 15 16 17 18 19 20 21 22 23 e
24 25 m*W4
- wP
+%
9 a
4g,
m